The Supreme Court has ruled that the absence of a motive does not invalidate a conviction when there is strong and unbroken circumstantial evidence pointing to the accused’s guilt. This landmark judgment came while dismissing an appeal by Subhash Aggarwal, who was convicted of murdering his son using a licensed firearm.
"When the circumstances are very convincing and provide an unbroken chain leading only to the conclusion of guilt of the accused and not to any other hypothesis; the total absence of a motive will be of no consequence," observed the Court.
Case Background
The case revolved around a tragic incident of alleged filicide. Subhash Aggarwal, the father of the deceased, had tried to mislead his family and neighbours by claiming his son died by suicide using a screwdriver. However, the post-mortem revealed the cause of death was a gunshot wound from close range, and no blood was found on the screwdriver.
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The Court highlighted that the accused was the first to find the body and had gunshot residue on his right hand, which was his dominant hand. This physical evidence directly contradicted his version and supported the prosecution’s case.
"Motive is not imperative if there are very strong circumstances pointing to the guilt of the accused,” the Court stated, adding, “Motive remains hidden in the inner recesses of the mind of the perpetrator, which cannot, oftener than ever, be ferreted out by the investigation agency."
The defence argued that there was no reason for the father to kill his only son and claimed police fabrication. However, the Court noted that the explanation given under Section 313 CrPC about gunshot residue was false and unconvincing. The gun, a small double-barreled weapon without a butt, was in the father’s custody and could be fired with one hand.
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The Supreme Court referred to previous decisions, including Suresh Chandra Bahri v. State of Bihar, where it was held that the absence of motive cannot nullify strong circumstantial evidence. Similarly, it cited Sukhpal Singh v. State of Punjab, stating that while motive strengthens a case, its absence is not fatal.
"It cannot be declared as a general proposition of universal application that, in the absence of motive, the entire inculpatory circumstances should be ignored and the accused acquitted,” the Court concluded.
In this case, the combination of the father’s false claims, physical evidence like gunshot residue, and the testimony of family members and neighbours created a complete chain of circumstances, leading to the confirmation of the life sentence awarded by the Trial Court and upheld by the High Court.
"We find absolutely no reason to interfere with the conviction and sentence of the accused as handed down by the Trial Court and confirmed by the High Court," said the bench comprising Justices Sudhanshu Dhulia and K. Vinod Chandran.
Case Title: SUBHASH AGGARWAL Versus THE STATE OF NCT OF DELHI
Appearance:
For Petitioner(s) Mr. Varun Dev Mishra, AOR Ms. Mrinmoi Chatterjee, Adv. Ms. Kirti Lal, Adv.
For Respondent(s) Mr. Vikramjeet Banerjee, A.S.G. (NP) Mr. Mukesh Kumar Maroria, AOR Mr. Vijay Awana, Adv. Mr. Pratap Venugopal, Adv. Mr. Bhakti Vardhan Singh, Adv. Mr. P V Yogeswaran, Adv. Ms. Aakanksha Kaul, Adv.
