Vaibhav v. State of Maharashtra: Supreme Court Cautions Against Overreliance on Circumstantial Evidence

Introduction

In Vaibhav v. State of Maharashtra (2025 INSC 800), the Supreme Court overturned the appellant's conviction for murder under Section 302 IPC, delivering crucial guidance on the standards for circumstantial evidence.

Background

The case involved the death of the appellant's friend Mangesh, allegedly caused by a gunshot from the appellant's father's service pistol. The conviction was based entirely on circumstantial evidence.

The Court's Analysis

• Chain of Circumstances: Prosecution must establish an unbroken chain pointing only to guilt
• Forensic Evidence: Inconsistencies in bullet trajectory raised reasonable doubt
• Direct Link: No forensic proof directly linked the accused to the firing

Standards for Circumstantial Evidence

The Court reiterated the five-fold test for circumstantial evidence: circumstances must be fully established, point only to accused's guilt, be conclusive, exclude every hypothesis except guilt, and form a complete chain.

Caution to Courts

This judgment cautions trial courts against mechanical reliance on circumstantial evidence without rigorous application of established legal standards.