Subhash Aggarwal v. The State of NCT of Delhi

Criminal Appeal · 2025 INSC 499Decided 17 Apr 2025
Criminal Appeal (arising out of SLP (Crl.) No. 1069 of 2025)
Justice Sudhanshu Dhulia · Justice K. Vinod Chandran

Background

A father was convicted by the Trial Court of shooting his youngest son dead, a conviction upheld by the High Court. He claimed the death was a suicide, and that there was no motive for a father to kill his only son. The prosecution's case rested entirely on circumstantial evidence: gunshot residue on the accused's hand, the trajectory and range of the fatal shot, and the accused's own conflicting explanations to family and police immediately after the death.

Decision Breakdown

The Supreme Court dismissed the appeal and confirmed the conviction. It found that medical and ballistic evidence ruled out a self-inflicted wound (the shot was fired from close range but not contact range, and the gun had no butt yet could be fired one-handed), and that gunshot residue was found only on the accused's right hand, matching his own explanation that he alone could access the weapon. The accused had first falsely told family and a neighbour that his son died from a screwdriver wound (no blood was found on the screwdriver), and gave a further false account in his statement to the court about how the residue got on his hands. The Court held that while absence of motive can favour an accused in a purely circumstantial case, it cannot outweigh a complete and unbroken chain of incriminating circumstances, especially reinforced by demonstrably false explanations from the accused.

Lesson Learnt

In a case built on circumstantial evidence, an accused's demonstrably false explanations to family, neighbours, and the court become an additional link strengthening the prosecution's case, and the absence of an apparent motive will not save a conviction where the chain of proven circumstances is otherwise complete.

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