Motive Is Insignificant When There Is Direct Evidence Proving The Guilt Of Accused: Supreme Court

While upholding the accused conviction for committing a day-light murder, the Supreme Court held that if there's a direct ocular piece of evidence inspiring the confidence of the court then the motive behind the commission of the offence would be of little relevance and the prosecution need not prove the motive of the accused in the commission of the crime

“The argument of the defence that the prosecution has not been able to establish any motive on the accused for committing this dastardly act is in fact true, but since this is a case of eyewitness where there is nothing to discredit the eye-witness, the motive itself is of little relevance.”, the Bench Comprising Justices Sudhanshu Dhulia and PB Varale said.

The Judgment authored by Justice Sudhanshu Dhulia stated that the lack or absence of motive on the part of the accused is inconsequential when direct evidence establishes the crime.

“In Shivaji Genu Mohite v. State of Maharashtra, it was held that it is a well-settled principle in criminal jurisprudence that when ocular testimony inspires the confidence of the court, the prosecution is not required to establish motive. Mere absence of motive would not impinge on the testimony of a reliable eye-witness. Motive is an important factor for consideration in a case of circumstantial evidence. But when there is direct eye witness, motive is not significant.”, the court observed.

In the present case, the appellant was charged with Section 302 of IPC for committing a daylight murder. The only direct eye-witness to the incident narrates the entire sequence of events as to how the accused stabbed the deceased to death and how she watched from a short distance the act being committed before her, and how all this happened in quick time.

A blood-stained knife was recovered from the accused, a Forensic report revealed that the blood of the deceased was found to be matching with the blood found on the knife, which was recovered from the accused/appellant.

Observing that the entire evidence put together by the prosecution does establish the guilt of the accused beyond a reasonable doubt. The court observed as follows:

“in view of the fact that the blood of the deceased clearly matches with the blood which was found on the knife, together with the ocular evidence in the form of an eyewitness (PW-2), who is a reliable eye-witness of the incident. We can also not lose sight of the fact that the murder, the arrest of the accused and the recovery of the knife from him happened in quick succession, with a very little time gap.”

Based on the above premise, the court dismissed the appeal and directed the appellant/accused to surrender before the Trial Court to undergo the remaining part of the sentence.

Counsel For Appellant(s) Ms. Richa Kapoor, AOR Mr. Deepak Singh, Adv.

Counsel For Respondent(s) Mrs. Aishwariya Bahti, A.S.G. (NP) Mr. Mukesh Kumar Maroria, AOR Mrs. Shivika Mehra, Adv. Mrs. Rajeshwari Shankar, Adv. Mr. Alankar Gupta, Adv. Mr. Akshaja Singh, Adv.

Case Title: CHANDAN VERSUS THE STATE (DELHI ADMN.)

Citation : 2024 LiveLaw (SC) 288

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