Summary of Landmark judgment

Case: Chandan v. The State (Delhi Admn.)

Date of Order / Judgment: 5th April, 2024

The Matter Heard by Bench: Justice Sudhanshu Dhulia and Justice PB Varale


In the case in hand, the Appellant was charged with Section 302 of Indian Penal Code for committing murder. The whole sequence of events was narrated by the only direct eye- witness to the incident as to how the accused stabbed the deceased to death. A blood-stained knife was recovered from the accused and the forensic report revealed that the blood of the deceased was found to be matching with the blood found on the knife which was recovered from the Accused/Appellant. The Appellant/Accused was convicted under Section 302 of the Indian Penal Code. Aggrieved by this decision, an appeal was filed in the High Court. However, the High Court upheld the conviction and sentence. Against the decision of the High Court, the Appellant approached the Supreme Court.


Whether Motive is significant when there is direct evidence proving the guilt of the accused?


The Supreme Court observed that “The argument of the defence that the prosecution has not been able to establish any motive on the accused for committing this dastardly act is in fact true, but since this is a case of eyewitness where there is nothing to discredit the eye-witness, the motive itself is of little relevance.”


The Supreme Court dismissed the appeal and held that that if there is a direct ocular piece of evidence inspiring the confidence of the Court then the motive behind the commission of the offence would be of less relevance. The Court also held that the Prosecution need not prove the motive of the accused in the commission of the crime.