Summary and Analysis of Vaibhav v. State of Maharashtra (2025 INSC 800)

Case Details:

2025 INSC 800 (Supreme Court of India)
Bench: Justice B.V. Nagarathna and Justice Satish Chandra Sharma

1. Background of the Case

• Parties:
  Appellant: Vaibhav (accused) – A first-year medical student at Bagla Homeopathy Medical College.
  Respondent: State of Maharashtra.

• Key Incident:
  On 16.09.2010, Vaibhav and his friend Mangesh (deceased) left college together on Mangesh’s scooter.
  Mangesh’s body was found the next day with a gunshot wound from a 9mm pistol belonging to Vaibhav’s father (PW-12, a police officer).
  Vaibhav was convicted under Sections 302 (murder), 201 (destruction of evidence) IPC, and Section 25(1)(a) of the Arms Act by the Trial Court and Bombay High Court.

2. Key Legal Questions

1. Whether the circumstantial evidence conclusively proved Vaibhav’s guilt for murder?

2. Whether the trajectory of the bullet supported the prosecution’s theory of homicidal death?

3. Whether the absence of motive and inconclusive medical evidence created reasonable doubt?

4. Whether the High Court erred in relying on Section 8 of the Evidence Act (conduct of accused) to infer guilt?

3. Supreme Court’s Analysis

A. Circumstantial Evidence

• The prosecution relied on:
  Last seen theory (Mangesh was with Vaibhav before death).
  Admitted conduct of Vaibhav (removing the body, cleaning the crime scene).
  Pistol ownership (belonging to Vaibhav’s father, with one bullet missing).

• Court’s View:
  The chain of circumstances was incomplete. No direct evidence linked Vaibhav to pulling the trigger.
  Missing links:
  No ballistic report confirming the pistol’s use.
  No motive established (Vaibhav and Mangesh were friends).

B. Bullet Trajectory and Medical Evidence

• PW-9 (Doctor) testified:
  The bullet entered through the eye and exited the lower skull, then hit a ventilator above the door.
  Inconclusive on whether the death was homicidal or accidental.

• Court’s View:
  The upward trajectory suggested the deceased was sitting and looking down at the pistol (consistent with accidental firing).
  Prosecution failed to explain how the bullet could hit the ventilator if fired by Vaibhav from a standing position.

C. Absence of Motive

• Prosecution’s Failure:
  No evidence of enmity between Vaibhav and Mangesh.

• Court’s View:
  In circumstantial cases, motive is a relevant but not decisive factor (Anwar Ali v. State of HP).
  Complete absence of motive weighs in favor of the accused.

D. Conduct of the Accused (Section 8, Evidence Act)

• High Court’s Reasoning:
  Vaibhav’s actions (hiding the body, false inquiries) indicated a guilty mind.

• Supreme Court’s Rebuttal:
  Conduct was consistent with accidental death (fear of father’s reaction).
  Suspicion ≠ Proof: Prosecution must prove guilt beyond doubt, not rely on post-incident behavior alone.

4. Conclusion and Directions

• Judgment:
  Acquitted under Section 302 IPC and Arms Act due to reasonable doubt.
  Conviction upheld under Section 201 IPC (destruction of evidence) but sentenced to time already served.

• Key Precedents Cited:
  Anwar Ali v. State of HP (2020): Motive in circumstantial cases.
  Shivaji Patil v. State of Maharashtra (2021): Chain of circumstances must be complete.
  Nandu Singh v. State of MP (2022): Absence of motive favors the accused.