One-Sided Infatuation Not Proof Of Motive; 'Last Seen' Evidence Must Be Cogent To Establish Guilt: Supreme Court

"The motive is inherently weak and insufficient to anchor a conviction for murder... at its highest, the evidence depicts a one-sided infatuation harboured by accused no. 2 towards accused no. 1." Supreme Court, in a significant judgment dated July 13, 2026, held that a one-sided infatuation cannot be equated to a reciprocal love affair to establish a motive for murder in cases resting on circumstantial evidence.

A bench of Justice Sanjay Karol and Justice Prasanna B. Varale observed that the prosecution must establish a complete and unbroken chain of circumstances that unerringly points to the guilt of the accused, excluding every other reasonable hypothesis of innocence. The Court noted that suspicion, however strong, cannot take the place of legal proof in criminal jurisprudence.

The case involved the murder of Kiran Suryawanshi, whose body was intercepted by the police while being transported on a motorcycle by two men, Prakash (A2) and Dnyaneshwar (A3). The prosecution alleged that the deceased’s wife, Monika (A1), had an extramarital affair with Prakash and conspired with the others to eliminate her husband. While the Trial Court convicted the accused for murder and conspiracy, the High Court acquitted them of the major charges, sustaining only the conviction for destruction of evidence against the individuals caught transporting the body.

The primary question before the court was whether the circumstantial evidence, including the alleged motive of an illicit affair and the 'last seen' theory, was sufficient to establish a chain of guilt for the charge of murder. The court was also called upon to determine if the recovery of incriminating articles from a public place without proper sealing held any evidentiary value under Section 27 of the Indian Evidence Act.

One-Sided Infatuation Does Not Prove Motive For Murder

The Supreme Court analyzed the alleged motive of an extramarital affair between accused no. 1 and accused no. 2. The prosecution relied on testimonies claiming the neighbor boasted about the wife being his lover and showed her photograph on a computer. However, the Court found this evidence to be severely lacking in proving a reciprocal relationship.

The bench noted that the evidence, at its highest, only suggested a one-sided infatuation by the neighbor. There was no cogent evidence proving that the wife reciprocated these feelings or harboured any animosity toward her husband. The Court emphasized that mere production of telephone records does not substitute for substantive proof of an illicit affair leading to a conspiracy for murder.

"The motive is inherently weak and insufficient to anchor a conviction for murder."

Limitations Of The 'Last Seen' Theory

Regarding the 'last seen' theory, the prosecution examined a colleague who claimed to have dropped the deceased at his home on the night of the incident. The Court found this testimony unreliable due to the witness's "unnatural conduct" in waiting outside the house without a logical reason.

The Court further observed that the wife had provided a probable defense under Section 313 CrPC, stating her husband had left the house to attend a party against her wishes. Given the prosecution’s failure to establish the exact time of death, the Court held that the 'last seen' evidence was a "weak type of evidence" that failed to bridge the gap between the last encounter and the discovery of the body.

Failure To Seal Recovered Articles Fatally Undermines Prosecution Case

The Court identified massive lapses in the handling of physical evidence, specifically the failure to seal recovered articles like a grinding stone and a syringe at the spot of seizure. Referring to the precedent in Ashraf Hussain Shah v. State of Maharashtra, the bench reiterated that the prosecution must prove that articles were kept in a sealed condition until they reached the Chemical Analyzer.

The bench observed that this strict procedural requirement is mandated to eliminate the suspicion of evidence planting. Furthermore, since the alleged murder weapon was recovered from a dumping place in a public area accessible to anyone, its evidentiary value was heavily diluted. The Court also found it physically impossible that no blood was found on the bedsheets if the victim was bludgeoned to death in his bed.

"A recovery made under Section 27 of the Indian Evidence Act, 1872 without affixing lac seals holds absolutely no evidentiary value."

Proof Of Agreement Essential For Charge Of Conspiracy

In addressing the charge under Section 120B IPC, the Court held that the prosecution failed to demonstrate a "meeting of minds" or an agreement to commit an illegal act. Citing State (NCT of Delhi) v. Navjot Sandhu, the Court noted that while conspiracies are often proved by circumstantial evidence, each incriminating circumstance must be clearly established.

The Court concluded that because the motive failed, the last-seen theory collapsed, and the forensic evidence was compromised, the chain of circumstances was broken. While the conviction of the two men caught red-handed with the body was sustained under Section 201 IPC for destruction of evidence, the acquittal of all accused for the charge of murder was upheld.

The Supreme Court dismissed the appeals filed by the State of Maharashtra, affirming the High Court's judgment. The Court ruled that the prosecution's case suffered from vital lacunae, and the hypothesis of guilt was not exclusively established. The bench maintained that in cases of circumstantial evidence, the circumstances must be conclusive in nature, establishing that the accused alone is the perpetrator.

Date of Decision: July 13, 2026