Case Summary: Vaibhav v. State of Maharashtra

1. Case Title: Vaibhav v. State of Maharashtra
2. Citation: Vaibhav v. State of Maharashtra, MANU/SC/0806/2025, AIR 2025 SC 2996, 2025 ALLMR (Cri) 3229, 2025 (3) Bom CR (Cri) 68 (India).
3. Court: Supreme Court of India
4. Bench: B.V. Nagarathna & S.C. Sharma, JJ.
5. Date of Judgment:June 4, 2025
6. Relevant Statutes / Key Provisions:

• Indian Penal Code, No. 45 of 1860, Sections: 302, 201, 34
• Arms Act, No. 54 of 1959, Sections: 5, 25(1)(a).
• Indian Evidence Act, No. 1 of 1872, Sections 8, 27

Facts

Vaibhav and Mangesh were roommates and close friends who were both in the same first-year class at Bagla Homeopathy Medical College, Chandrapur. On September 16, 2010, they left college together on the scooter owned by Mangesh, and later on that same day they went to Vaibhav’s house in Chikanghar. That evening, when Mangesh had not returned home, Mangesh’s father reported him missing.

On September 17, 2010, Mangesh was found dead lying in the courtyard behind Vaibhav’s house. Mangesh had died of a fatal gunshot wound to the head delivered by a 9mm service pistol, which belonged to Vaibhav’s father, a police officer.

The evidence put forth by the prosecution alleged that Vaibhav shot Mangesh in his home, and after the shooting, moved Mangesh’s body and cleaned up the crime scene. Likewise, Vaibhav was charged with murder pursuant to Section 302 IPC, illegal use of a firearm pursuant to Section 201 IPC, and illegal possession of a firearm pursuant to Section 25 of the Arms Act. His friend Vishal was only charged with concealment of evidence pursuant to Section 201 IPC.

Vaibhav was convicted of murder, illegal use of a firearm, and causing the disappearance of the evidence. Vaibhav then appealed and the Bombay High Court affirmed Vaibhav’s conviction, but acquitted Vishal. Vaibhav continued to challenge his conviction and appealed to the Supreme Court of India.

Issues addressed

The evidence put forth by the prosecution alleged that Vaibhav shot Mangesh in his home, and after the shooting, moved Mangesh’s body and cleaned up the crime scene. Likewise, Vaibhav was charged with murder pursuant to Section 302 IPC, illegal use of a firearm pursuant to Section 201 IPC, and illegal possession of a firearm pursuant to Section 25 of the Arms Act. His friend Vishal was only charged with concealment of evidence pursuant to Section 201 IPC.

Vaibhav was convicted of murder, illegal use of a firearm, and causing the disappearance of the evidence. Vaibhav then appealed and the Bombay High Court affirmed Vaibhav’s conviction, but acquitted Vishal. Vaibhav continued to challenge his conviction and appealed to the Supreme Court of India.

Issues addressed

1. If the prosecution proved, to the necessary standard, that Vaibhav killed Mangesh. 
2. Whether an unbroken chain of circumstantial evidence exclusively pointed to Vaibhav’s guilt.  
3. If the accidental shooting defence was, on the basis of the evidence, a reasonable explanation. 
4. If circumstances after the event, for example, concealing or hiding evidence, were sufficient to prove murder. 
5. What the absence of motive determined in a case based on circumstantial evidence only.

Arguments

Appellant (Vaibhav)

The findings of PW-9 (the person who found the body) reveal that the bullet entered through the eye and exited through the base of the skull, shattering a ventilator above, which is sufficient to draw an inference of unintentional discharge. PW-9’s evidence clearly stated that no conclusion could be reached about whether the death was homicidal. There was no motive shown; Vaibhav and Mangesh were friends. The indicators presented by the prosecution were insufficient to establish guilt beyond a reasonable doubt; a suspect’s behavior alone cannot replace specific evidence.

Respondent (State of Maharashtra)

Vaibhav’s disposal of a body and cleaning of the scene demonstrated concealing intention. The agency gun belonged to his father, and Vaibhav was aware of it. Mangesh was last seen alive in the company of Vaibhav, which provided additional circumstantial evidence to the last opportunity argument.

Judgement

Vaibhav’s conviction under Section 302 IPC and Section 25 Arms Act has been overturned by the Supreme Court. The Court stated: The prosecution case is at odds with the evidence, and in particular with the medical evidence that concerns the bullet trajectory of the fired rounds. The High Court’s endeavor to re-frame the issue of accidental death for the right standard of proof on a probability basis, was simply misplaced. Suspicion alone, based on post hoc conduct, cannot displace actual evidence of guilt.  The lack of motive, at that point, in a case based solely on circumstantial evidence was a significant factor for the accused. Vaibhav’s conviction under Section 201 IPC was upheld, however; he had confessed to the acts of moving the bodies and cleaning the scene of the crime. The sentence was reduced to time served.

Ratio Decidendi

A homicide conviction based solely on circumstantial evidence is valid only if the circumstantial evidence is cumulative and if all other hypothesized circumstances consistent with innocence are excluded (Sharad Birdhichand Sarda v. State of Maharashtra, (1984) 4 S.C.C. 116 (India)). Suspicion however serious is not a substitute for proof (Hanumant Govind Nargundkar v. State of M.P., A.I.R. 1952 S.C. 343 (India)). The prosecution has to prove guilt beyond reasonable doubt, whereas a defendant only has to establish a probable defence(Appu v. Government of NCT Delhi, (2016) 12 S.C.C. 641 (India)).

Obiter Dicta

Concealment can be a crime punishable by the law, yet even these suspects could act out of fear, rather than culpability, and a suspect concealing may well be an immature young offender with no antecedents. Section 8 of the Indian Evidence Act speaks to relevant evidence which arose and has an affectionate relationship to subsequent conduct, but such evidence will not be sufficient to support a conviction for murder without other corroboration.

Disposition

The Supreme Court acquitted Vaibhav of the murder charges under Section 302 IPC, and the Arms Act Section 25 and upheld the conviction under Section 201 IPC with a sentence of the time already served.