Who Pulled the Trigger? When Bullet's Path Defies Prosecution’s Story, Doubt Must Go to Accused: Supreme Court Acquits Man of Murder

“Suspicion, However Grave, Cannot Substitute Proof in Criminal Trials”: On June 4, 2025, the Supreme Court of India setting aside the conviction of a medical student accused of murdering his friend by firearm in 2010. The Court ruled that the prosecution failed to conclusively prove homicide, noting that the trajectory of the bullet and the medical evidence aligned more closely with accidental death. "Mere suspicion, no matter how grave, cannot take the place of proof in a criminal trial," the bench led by Justices B.V. Nagarathna and Satish Chandra Sharma declared.

A Friendship Ends in Tragedy

The case concerned Vaibhav and Mangesh, first-year students at a homeopathy medical college in Maharashtra. On 16 September 2010, they left college together and went to Vaibhav's house. Later that day, Mangesh was reported missing, and his dead body was discovered the next morning in the courtyard behind Vaibhav’s home.

The prosecution claimed that Vaibhav shot Mangesh using his father's service pistol (a 9mm firearm) and attempted to dispose of the body with help from friends. The trial court convicted Vaibhav under Sections 302 (murder), 201 (causing disappearance of evidence), and under the Arms Act. The Bombay High Court upheld his conviction, relying heavily on circumstantial evidence and the appellant’s conduct after the incident.

 “Who Pulled the Trigger?”

The Court began by emphasizing the burden of proof on the prosecution: “Despite two rounds of litigation, the question is yet to find an answer – who pulled the trigger?”

Though Vaibhav admitted to cleaning up the crime scene, removing the body, and returning the pistol under the mattress, he consistently maintained that the death was accidental. The Court noted that both Vaibhav and his father (a police officer) admitted the firearm was in the house, and medical testimony (PW-9) could not determine whether the death was homicidal or accidental.

The Court highlighted a critical medical inconsistency:

“The bullet entered through the eye of the deceased and exited from the lower part of the skull… then hit a ventilator located above the door — suggesting that the bullet travelled upward after exit.”

Such an upward trajectory post-exit, the Court found, was inconsistent with a straightforward homicidal shot and more compatible with an accidental self-inflicted discharge from close range.

Circumstantial Chain Is Incomplete

Rejecting the High Court’s reasoning, the Supreme Court stated:

“The version of the prosecution suffers from inherent inconsistencies and doubts… the inability of the appellant to explain certain circumstances could not be made the basis to relieve the prosecution from discharging its primary burden.”

The bench reiterated the legal principle that “in a case based on circumstantial evidence, it must be established that the chain of circumstances is complete.” Not only was the prosecution's theory incomplete, but the accused’s consistent version — of an accidental death out of curiosity — was “more probable” and “supported by medical evidence.”

On Motive: “Absence of Motive Is Not Fatal — But It Does Weigh in Favour of the Accused”

The Court noted that no motive was established. The two young men were friends; even Mangesh’s father confirmed there was no enmity. While the absence of motive is not always fatal to the prosecution’s case, in circumstantial matters it can tip the scale.

“A complete absence of motive, although not conclusive, is a relevant factor which weighs in favour of the accused.”

On Conduct After Death: “Fear of Father, Not Guilt of Crime”

The Court acknowledged Vaibhav’s actions — cleaning the scene, moving the body, pretending ignorance — but attributed them to fear, not malice:

“A young boy studying in first year of college, with no criminal background… would certainly have become scared… although punishable in law, [his conduct] does not become so unnatural that it could be made the basis to convict him for murder.”

Acquittal for Murder, Conviction for Tampering Evidence

While acquitting Vaibhav of murder and illegal arms possession, the Court maintained his conviction under Section 201 IPC for destruction of evidence. However, it sentenced him to the period already undergone in custody, recognizing that his actions post-incident, though legally culpable, were not indicative of murderous intent.

“The circumstantial evidence on record is not consistent and leaves a reasonable possibility of an alternate outcome i.e., of innocence.”

A Cautionary Reminder on the Limits of Inference

This judgment serves as a vital reaffirmation that criminal convictions must rest on rock-solid foundations. Where the chain of evidence is broken or compatible with alternate theories — especially in circumstantial cases — courts must err on the side of acquittal.

“Suspicion, however grave, cannot substitute proof in criminal trials,” the Court warned, reaffirming the bedrock principles of criminal jurisprudence.

Date of Decision: June 4, 2025