Supreme Court Upholds Conviction in Father-Son Murder Case: Key Arguments and Analysis
The Supreme Court of India recently delivered a judgment in the case of Subhash Aggarwal vs. The State of NCT of Delhi, upholding the conviction of a father accused of murdering his son. The case presented a complex interplay of forensic evidence, witness testimonies, and legal principles surrounding motive and circumstantial evidence. This blog post provides a detailed narrative of the case, including the arguments presented by both parties and the court’s reasoning.
The case originated from an incident on the night of December 14/15, 2012, when the appellant’s son was found dead in their home with a gunshot wound. The appellant, Subhash Aggarwal, was convicted under Section 302 of the Indian Penal Code (IPC) and Sections 25/27 of the Arms Act by the Trial Court, a decision later confirmed by the High Court. The Supreme Court’s judgment delves into whether the death was a suicide or homicide, the reliability of forensic evidence, and the significance of motive in criminal cases.
Arguments of the Appellant (Subhash Aggarwal):
The appellant’s counsel argued that the prosecution failed to establish a motive for the crime. They emphasized that the appellant maintained good relations with his son, as corroborated by testimonies from family members. The counsel also questioned the forensic evidence, stating that the gunshot residue found on the appellant’s right hand could not conclusively prove his guilt. They contended that the absence of gunshot residue analysis from the deceased’s hands weakened the prosecution’s case. Additionally, the appellant claimed that he was framed and that the police had coerced him into signing blank papers.
Arguments of the Respondent (State of NCT of Delhi):
The State argued that the appellant’s conduct immediately after the incident was highly suspicious. Witnesses testified that the appellant tried to convince them that the death was a suicide caused by a screwdriver, despite the absence of blood stains on the screwdriver. The State highlighted the forensic evidence, including the gunshot residue on the appellant’s right hand and the trajectory of the bullet, which indicated a close-range shot inconsistent with suicide. The State also dismissed the appellant’s claim of police coercion as a fabrication.
Supreme Court’s Observations and Decision:
The Supreme Court meticulously examined the evidence and testimonies. The court noted, “The accused had a case that the deceased died by a self-inflicted injury with a screwdriver and he does not have any explanation as to how he detected the body in the night when everybody was asleep.” The court found the appellant’s explanation implausible and concluded that his conduct pointed to guilt.
The court also addressed the forensic evidence, stating, “The gunshot residue found on the right hand of the accused also has not been explained properly by him and the version in the Section 313 statement has been found to be a deliberate falsehood.” The court relied on medical and ballistic expert testimonies to determine that the wound was not self-inflicted.
On the issue of motive, the court observed, “Motive remains hidden in the inner recesses of the mind of the perpetrator, which cannot, oftener than ever, be ferreted out by the investigation agency.” While acknowledging the absence of a clear motive, the court emphasized that the circumstantial evidence formed an unbroken chain leading to the appellant’s guilt.
The court concluded, “The circumstances coupled with the falsity of the claim made by the accused immediately after the detection of the body, to the onlookers and the false explanation given by the accused in his statement under Section 313, regarding both his hands having been forcefully smeared with gunshot residue provides further links in the chain of circumstances which is complete and leads only to the hypothesis of the guilt of the accused and not to any hypothesis of innocence.”
The Supreme Court dismissed the appeal, upholding the appellant’s conviction and sentence. The judgment underscores the importance of forensic evidence and the role of circumstantial evidence in criminal cases, even in the absence of a clear motive.
Petitioner Name: Subhash Aggarwal.Respondent Name: The State of NCT of Delhi.Judgment By: Justice Sudhanshu Dhulia, Justice K. Vinod Chandran.Place Of Incident: Delhi.Judgment Date: 16-04-2025.Result: dismissed.
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