Motive Not Essential with Strong Circumstantial Evidence
The Supreme Court ruled that lack of motive does not weaken the prosecution’s case if the circumstantial evidence clearly proves the accused’s guilt. The Court emphasized that when evidence forms an unbroken chain pointing only to the accused’s guilt, the absence of motive becomes irrelevant.
The bench, comprising Justices Sudhanshu Dhulia and K Vinod Chandran, noted that motive holds value in linking evidence but loses weight when direct or convincing circumstantial proof exists. They stressed that even a strong motive alone cannot lead to conviction without reliable evidence.
Case Background: Father Kills Son with Licensed Gun
The case involved a man convicted of murdering his son using a licensed revolver. The incident occurred at night while the rest of the family was asleep. The father, who discovered the body, falsely claimed his son died by suicide using a screwdriver. However, the object had no bloodstains.
Gunshot residue (GSR) was found on the father’s dominant hand. This indicated he had fired the weapon at close range. The evidence contradicted his claim and supported the prosecution’s version of murder.
Petitioner’s Argument: No Motive Means No Crime
The accused argued that his son had taken his own life with the licensed gun. He maintained that the prosecution failed to establish any motive for him to kill his son. On this basis, he sought acquittal.
However, both the Trial Court and the High Court found him guilty. The Supreme Court was his final appeal.
Supreme Court’s Ruling: Circumstantial Evidence Is Sufficient
Justice K Vinod Chandran, writing the judgment, confirmed that strong circumstantial evidence can support a conviction even without proving motive. The Court relied on the principle from Suresh Chandra Bahri v. State of Bihar, where it held that absence of motive cannot by itself dismiss a criminal case.
The Court observed that motive often lies deep within the mind and is hard to uncover. It clarified that lack of motive might favor the accused but cannot nullify clear and complete evidence pointing to guilt.
Final Verdict: Life Sentence Upheld
The Court rejected the suicide theory. It found that the accused had exclusive control over the firearm. Witnesses confirmed that only he could operate the weapon. The claim that his children had hidden the gun was deemed implausible.
The Court also noted strained relationships within the family. It concluded that convincing circumstantial evidence and witness testimony established guilt beyond doubt.
The Supreme Court upheld the life imprisonment sentence, confirming that motive is not essential when the evidence is overwhelming.
