12 June 2025 Legal Updates

'NO INFERENCE OF GUILT FROM MERE ACT OF HIDING DEAD BODY': SUPREME COURT ACQUITS YOUTH IN MURDER CASE OVER ACCIDENTAL GUNSHOT

(a) Case Title:

• Vaibhav v. The State of Maharashtra

(b) Court:

• Supreme Court of India

(c) Date of Decision:

• June 4, 2025

(d) Bench:

• Justice B.V. Nagarathna and Justice Satish Chandra Sharma

Facts of the Case

Vaibhav (appellant) and Mangesh (deceased) were friends and first-year students at Bagla Homeopathy Medical College, Maharashtra. On September 16, 2010, both left college together on Mangesh's scooter and went to Vaibhav's house. Mangesh failed to return home; his father filed a missing report. Next day, Mangesh's dead body was found in the courtyard behind Vaibhav's residential house

HISTORY OF PROCEEDINGS:

• Trial Court convicted Vaibhav under Section 302 IPC (Murder), Section 201 IPC (Destruction of evidence) and Section 25(1)(a) Arms Act (Illegal possession/use of firearms)
• Bombay High Court upheld the conviction in 2012. The case based entirely on circumstantial evidence.

Prosecution Case

Alleged that Vaibhav murdered Mangesh using his father's 9mm service pistol

Defense Case

Vaibhav claimed that Mangesh's death was accidental. According to him while he went to change clothes, Mangesh found the service pistol, got curious, looked into it from close range, and accidentally pulled the trigger. Out of fear of his father, Vaibhav removed the body and cleaned the crime scene.

Key Evidence Analyzed by Supreme Court

1. Medical Evidence - Bullet Trajectory

• Critical finding: Bullet entered through Mangesh's eye, exited from lower back of skull, then travelled upward to hit a ventilator above the door
• Court's analysis: This upward trajectory after downward exit was inconsistent with homicidal death
• Conclusion: Trajectory supported accidental death theory (victim looking down into pistol barrel from close range)

2. Medical Expert Testimony

Medical witness could not conclusively determine whether death was homicidal or accidental. The following characteristics were found to be consistent with accidental gunshot: Single wound, Close-range firing, No fingerprints linking appellant to weapon.

3. Absence of Motive

No evidence of enmity between the two friends. All witnesses confirmed their friendly relationship. Based on precedents, Court noted that in cases of circumstantial evidence, complete absence of motive weighs in favor of accused

4. Subsequent Conduct

Vaibhav's actions (removing body, cleaning scene, making false inquiries) were suspicious. The Court observed that this action was consistent with fear rather than guilt, especially for young student with no criminal background.

Supreme Court's Decision

Verdict: Appeal Partially Allowed. The Court acquitted the appellant on charges under Section 302 IPC (Murder) and Section 25(1)(a) Arms Act (Illegal use of firearm) and upheld conviction under Section 201 IPC (Destruction of evidence).

Key Legal Principles

• 1. Circumstantial Evidence: Must form a complete chain pointing exclusively to guilt. No reasonable alternative theory should be possible. Chain must be consistent with conclusion of guilt only
• 2. Burden of Proof in Criminal Cases: Primary burden on prosecution to prove guilt beyond reasonable doubt. Only after prosecution discharges this burden does burden shift to accused to explain circumstances. Accused's inability to explain certain aspects cannot relieve prosecution of its evidentiary burden
• 3. Two Views Rule: When two reasonable interpretations are possible from evidence, view favourable to accused should be adopted. Benefit of counter possibility goes to the accused

IF ORIGINAL SALE AGREEMENT IS UNREGISTERED, REGISTRATION OF SUBSEQUENT INSTRUMENT WON'T CONFER TITLE: SUPREME COURT

(a) Case Title:

• Mahnoor Fatima Imran & Ors. v. M/s Visweswara Infrastructure Pvt. Ltd & Ors.

(b) Court:

• Supreme Court of India

(c) Date of Decision:

• May 7, 2025

(d) Bench:

• Justice Sudhanshu Dhulia and Justice K. Vinod Chandran

Background

This case involves a complex land dispute over 53 acres in Survey No. 83/2 of Raidurg Panmaktha, Village Serilingampalle Mandal, Ranga Reddy District, Telangana. The original land (525+ acres) belonged to 11 individuals and had a "chequered career" under various land reform laws.

Key Facts

11 individuals originally owned 526.07 acres of land. The land was subject to Andhra Pradesh Land Reforms Act, 1976. According to the Act, 99.07 acres vested in the State Government since the year 1975 and 424.13 acres of land was later allotted to APIIC (Now TSIIC).

Disputed Transaction:

A Sale agreement dated March 19, 1982 was made between original owners and Bhavana Co-operative Housing Society. The Agreement later "validated" in 2006 by Assistant Registrar. This validation was declared fraudulent by District Registrar in the year 2015.

Legal Issues

• Whether writ petitioners had valid title based on registered sale deeds from Bhavana Society?
• Whether parties could prove actual physical possession?
• Whether unregistered sale agreements could confer valid title?

Supreme Court's Analysis

1. On Title

The Court found the title "suspect" and "prima facie fraudulent". Two different versions of the same agreement (dated 19.03.1982) existed with varying terms: Different extents of land (125-35 acres vs 99.17 acres); Different consideration amounts and payment terms and same boundaries despite different extents. These factors created an anomaly.

2. On Registration Requirements

Citing Suraj Lamp & Industries Pvt. Ltd. v. State of Haryana, the Court emphasized that: Immovable property can only be legally transferred through registered deed of conveyance. Unregistered agreements cannot confer valid title. Agreement-based transfers are not valid modes of transfer.

3. On Possession

The Court applied Balkrishna Dattatraya Galande v. Balkrishna Rambharose Gupta principle to hold:

• Actual and physical possession must be proved with evidence
• Mere interim court orders cannot establish possession
• Neither party adequately proved physical possession

Key Legal Principles

1. Property Transfer:

• Only registered deeds can validly transfer immovable property (Section 17, 49 of Registration Act)

2. Writ Jurisdiction:

Courts will not exercise extraordinary jurisdiction under Article 226 when:

• Title is suspect or fraudulent
• Possession is not clearly established
• Claims are based on invalid documents

3. Burden of Proof:

• In possession disputes, actual physical possession must be proved through credible evidence, not just legal presumptions

4. Land Reform Laws:

• Once land vests in the State under land ceiling/reform laws, private parties cannot claim ownership without following statutory procedures

Decision

The Supreme Court restored the Single Judge's order dismissing the writ petition and rejected the Division Bench's contrary finding. It found writ petitioners failed to establish valid title or possession and preserved State's right to invoke Land Reforms Act provisions.