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Vaibhav v. The State of Maharashtra

Criminal Appeal · 2025 INSC 800Decided 4 Jun 2025
Crl.A. No.-001643-001643 - 2012
Justice B.V. Nagarathna · Justice Satish Chandra Sharma

Background

Vaibhav and Mangesh were two friends and medical college classmates in Maharashtra who commuted together on a scooter. On 16.09.2010, after spending the day together, Mangesh went missing that evening and was found dead the next day. Investigation implicated Vaibhav, who was accused of shooting Mangesh with his father's licensed gun and, with the help of a friend, disposing of the body. The Trial Court convicted Vaibhav of murder, destruction of evidence, and an Arms Act offence, and the Bombay High Court upheld his conviction while acquitting his co-accused friend for want of evidence.

Decision Breakdown

The Supreme Court reiterated the settled rule that in cases resting purely on circumstantial evidence, the chain of circumstances must be complete and consistent only with guilt, with no reasonable possibility of innocence, and that the benefit of any genuine alternative view must go to the accused. After examining the record, the Court found the chain of circumstances relied upon by the trial court and High Court was not fully consistent and left open a reasonable possibility of an alternate, innocent explanation. It therefore partially set aside the conviction, acquitting Vaibhav of the murder (Section 302 IPC) and Arms Act charges, while sustaining his conviction under Section 201 IPC (destruction of evidence), for which he was sentenced to time already served.

Lesson Learnt

A conviction built solely on circumstantial evidence can survive only if the chain of proven facts is complete and points exclusively to guilt; where a reasonable alternative explanation remains open, the law requires that benefit to go to the accused, even years after conviction.

Official source (sci.gov.in)View Judgment (PDF)

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