New Delhi, May 31, 2025

The Supreme Court has reiterated that failure to establish motive in a criminal case is not fatal to the prosecution if the chain of circumstantial evidence is complete and points conclusively to the guilt of the accused.

The ruling came from a bench comprising Justices B.R. Gavai and Sandeep Mehta, while upholding the conviction of an individual accused of murder. The appellant had argued that the absence of a proven motive raised reasonable doubt about his involvement.

Key Observations

The Court emphasized that motive, while relevant, is not a sine qua non (essential element) in every case, particularly when the prosecution relies on direct or strong circumstantial evidence.

“It is well settled that if the prosecution proves a complete chain of circumstances which excludes every hypothesis except the guilt of the accused, the absence of motive does not necessarily result in acquittal,” the bench observed.

The Court relied on precedents like Sharad Birdhichand Sarda v. State of Maharashtra to support its conclusion, reinforcing the principle of inference-based conviction in the absence of direct evidence.

 Background

In the case at hand, the accused was convicted by a trial court and the conviction was upheld by the High Court. The conviction was based purely on circumstantial evidence including last-seen theory, recovery of incriminating material, and forensic linkage. The accused argued in the Supreme Court that the prosecution had not established any motive, making the conviction untenable.
However, the top court held that the established facts formed a consistent narrative, and there was no possibility of any other person being involved.

This ruling reinforces the legal position that motive, while helpful, is not indispensable in cases where circumstantial evidence independently and cogently points to the guilt of the accused.

It also serves as a reminder to trial courts to evaluate evidence holistically rather than hinge their conclusions solely on motive.

Commenting on the verdict, former judge and criminal law expert Justice (Retd.) Madan Lokur noted, “This is in line with existing jurisprudence. The absence of motive cannot be a defense if the evidentiary framework is tight and conclusive.”