Supreme Court: Whether failure to prove motive in the case based on circumstantial evidence is fatal to prosecution case?

It is trite law in the cases of circumstantial evidence when the chain of circumstances have been adequately proved to link to the culpability of the Accused, motive is irrelevant this principle is further echoed in the case of Mulakh Raj and Ors. v. Satish Kumar and Ors.   MANU/SC/0219/1992 : 1992:INSC:106 : (1992) 3 SCC 43 whereas in it was held as thus:

17..... Undoubtedly in cases of circumstantial evidences motive bears important significance. Motive always locks up in the mind of the Accused and some time it is difficult to unlock. People do not act wholly without motive. The failure to discover the motive of an offence does not signify its non-existence. The failure to prove motive is not fatal as a matter of law. Proof of motive is never an indispensable for conviction. When facts are clear it is immaterial that no motive has been proved. Therefore, absence of proof of motive does not break the link in the chain of circumstances connecting the Accused with the crime, nor militates against the prosecution case. {Para 23}

IN THE SUPREME COURT OF INDIA

Criminal Appeal No. 1063/2021

Decided On: 21.05.2026

Chetan Dashrath Gade Vs. The State of Maharashtra

Hon'ble Judges/Coram:

Pankaj Mithal and P.B. Varale, JJ.

Author: P.B. Varale, J.

Citation: MANU/SC/0507/2026,2026 INSC 522.

Read full judgment here: Click here.

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