Introduction
In criminal jurisprudence, motive in circumstantial cases has been the point of contention. Indian Supreme Court has developed its own approach consistently placing the necessity of motive against the right of physical material. In a recent landmark judgment, the Court reaffirmed that lack of motive is not determinative against the prosecution case if circumstantial evidence is a cogent complete and unbroken chain leading to the conclusion that the crime has been committed by the accused.
Background
Motive has always been a useful connecting link in circumstantial evidence cases alone. The reason is that motive gives the cause of the offence and enables the court to connect the accused with the offence where direct evidence is lacking. Indian courts have also held, however, that motive, though useful, need not be proved if the evidence otherwise proves guilt beyond reasonable doubt.
Earlier rulings, for example, *Sharad Birdichand Sarda v. State of Maharashtra* (1984), laid down that every link in the chain of circumstantial evidence must be unimpeachable and lead to nothing but the guilt of the accused alone. In recent cases, the Supreme Court has reiterated that the role of motive becomes more significant in circumstantial evidence cases, but lack of motive does not necessarily entitle the accused to be acquitted unless otherwise strong evidence is available.
Key Points
- Motive as a Link, not a Necessity: The Supreme Court has noted that motive is a material consideration and can add weight to the case of the prosecution, but it is not a sine qua non for conviction in all circumstantial evidence-based cases. Where the chain of circumstances is so tight that there is no reasonable doubt regarding the guilt of the accused, absence of motive will not vitiate the case.
- Chain of Circumstances Must Be Complete: It is the established principle of the Court that circumstantial evidence must be a chain which is complete and unbroken and from which no other conclusion could be drawn except the guilt of the accused. If there is a missing link in the chain, the accused is entitled to the benefit of doubt.
- Minimal Significance of Motive Where overwhelming Circumstantial Evidence exists: Where the circumstantial evidence is overwhelming and points directly to the guilt of the accused, lack of established motive is immaterial. On the other hand, where the evidence is weak or where there is no chain of circumstances, failure of motive is in favor of the accused and may result in acquittal.
- Judicial Precedent: Supreme Court has made it clear that though motive being established strongly, it cannot alone lead to conviction unless accompanied by other incriminating facts. Likewise, lack of motive by itself would not warrant acquittal if otherwise, the evidence is cogent.
Recent Developments
In a recent judgment pronounced in April 2025, the Supreme Court reiterated its stance again that a lack of adequate motive cannot form the foundation of acquittal when cogent circumstantial evidence demonstrates beyond all doubt the guilt of the accused. In this case, the appellant was found guilty of having murdered his son. The prosecution did not have motive but the circumstantial and forensic evidence, such as the presence of gunshot residue on the hand of the appellant and discrepancies in his explanation, created a rational and cohesive chain to his culpability.
The Court, affirming the conviction, placed emphasis on:
“When facts are strongly cogent and reveal a series of continuous circumstances ending only in the conclusion of the guilt of the accused and not in any other hypothesis; the absence of motive entirely will be of no use.”
This news reaffirms earlier jurisprudence under which the Court has held that motive could perhaps constitute a link of connection in a series of facts but its absence cannot be sufficient reason to hold back the case for trial if circumstantial evidence otherwise remains strong and cumulative.
Conclusion
The reaffirmation in recent years by the Supreme Court is on a low-key approach towards circumstantial evidence in criminal cases. Although motive is still a useful element of the chain of evidence, the lack of it does not acquit the accused if the rest of the evidence is so strong that it wipes out every reasonable hypothesis except guilt. The courts’ concern remains the completeness and integrity of the circumstantial evidence so that justice is not compromised by technicalities or absence of established motive where the facts speak themselves. This methodology strengthens the rule that the last test in criminal jurisprudence is proof beyond a reasonable doubt, realized through even-handed consideration of all available evidence.
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WRITTEN BY LALITHA SASANKA G
