In a significant judgment, the Supreme Court recently acquitted a college student named Vaibhav in a 2010 murder case in which his friend Mangesh was killed. The verdict came after the court found that the prosecution failed to produce a full and convincing chain of circumstantial evidence to justify the conviction.

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The case involved a tragic incident in which Mangesh, a first-year student at Bagla Homoeopathy Medical College, was found dead after Vaibhav went home. The prosecution had claimed that Vaibhav shot Mangesh with his father's licensed service pistol. However, Vaibhav argued that Mangesh accidentally shot himself while handling the weapon.

"The suspicion must have been substantiated by undisputed, credible, clear, consistent and reliable circumstantial evidence, which does not leave the possibility of any other theory." - Supreme Court

The trial and the High Court had convicted Vaibhav under Sections 302 and 201 read with Section 34 of the IPC and also under the Arms Act. These courts relied heavily on Vaibhav's conduct after the incident—such as removing the body, cleaning the blood-stained floor and visiting Mangesh's house to inquire about his well-being.

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However, the Supreme Court bench of Justices BV Nagarathna and SC Sharma rejected these convictions, and said that such conduct after the incident cannot in itself prove guilt. The court clarified that the prosecution did not prove a crucial fact—who pulled the trigger.

"The inability of the appellant to explain certain circumstances cannot be made a ground to absolve the prosecution of its primary onus." - Supreme Court

The court emphasised that the conduct, though questionable and legally punishable, may have been caused by panic. Vaibhav, a young student with no criminal record or motive, may have done so out of fear after witnessing the accidental shooting.

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"That his act of removing the body and hiding the belongings was a result of his fear of his father—it is quite natural." - Supreme Court

Moreover, forensic evidence supported Vaibhav's version. The trajectory of the bullet and the injury pattern matched with accidental firing, and no concrete motive was established by the prosecution.

"The complete absence of motive, though not conclusive, is a relevant factor which weighs in favour of the accused." - Supreme Court

While acquitting Vaibhav of charges under Section 302 of the IPC and the Arms Act, the court upheld his conviction under Section 201 of the IPC for causing disappearance of evidence. However, it reduced his sentence to the period already served.

Case Title: VAIBHAV VERSUS THE STATE OF MAHARASHTRA

Appearance:

For Appellant(s) Mr. Vipin Sanghi, Sr. Adv. Mr. Satyajit A. Desai, Adv. Mr. Siddharth Gautam, Adv. Mr. Ananya Thapliyal, Adv. Mr. Abhinav K. Mutyalwar, Adv. Mr. Sachin Singh, Adv. Ms. Anagha S. Desai, AOR

For Respondent(s) Mr. Aaditya Aniruddha Pande, AOR Mr. Siddharth Dharmadhikari, Adv. Mr. Bharat Bagla, Adv. Mr. Sourav Singh, Adv. Mr. Aditya Krishna, Adv. Mr. Adarsh Dubey, Adv.

In a significant ruling, the Jammu and Kashmir High Court has declared that any oral gift of agrarian land without prior approval under Section 31 of the J&K Agrarian Reforms Act, 1976, is legally void. The court emphasized that mutation based on such a gift must be re-examined and corrected according to the law.

This judgment came in the matter of Saja Begum vs Financial Commissioner Revenue J&K Govt. & Others, where the petitioner had challenged a writ court order that had invalidated the decision of the Financial Commissioner, which earlier had cancelled a mutation based on an oral gift.

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The division bench, comprising Justice Sanjeev Kumar and Justice Sanjay Parihar, overruled the writ court’s decision and restored the Financial Commissioner’s order. The court made it clear that the Agrarian Reforms Act overrides the earlier Alienation of Land Act, 1995, particularly due to Section 42, which nullifies conflicting provisions of the earlier law.

"The gift was not valid without the permission of competent authority. The requirement under Section 31 is mandatory, not a mere formality,"
— J&K High Court

The court pointed out that oral gifts, although not barred under Muslim law or the Transfer of Property Act, cannot override the mandatory requirements of the Agrarian Reforms Act, 1976, especially Section 31 and Rule 60. The court stressed that these provisions were enacted to safeguard land redistribution policies and the rights of tillers.

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Further, the court rejected the argument that the revision petition was time-barred, stating that illegality in land transfer cannot be validated by limitation.

"Once a transfer is legally prohibited, limitation cannot cure it. The Financial Commissioner acted rightly within revisional powers,"
— J&K High Court

Background of the Case

In 1996, Mst. Mugli had allegedly gifted 22 kanals and 13 marlas of agrarian land orally to her son. After her death in 2015, the land was mutated in 2017 in favor of all legal heirs. One of the daughters, the appellant, challenged the mutation, citing violation of Standing Order 23-A and the Agrarian Reforms Act, arguing that such a gift was illegal without official approval.

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The Financial Commissioner agreed in 2022 and cancelled the mutation. However, the son approached the writ court, which set aside the Financial Commissioner’s decision. Later, in a Letters Patent Appeal, the High Court restored the Commissioner’s order and directed authorities to re-examine the mutation.

"Revenue officials are to conduct a fresh inquiry into the impugned mutation and recast it in compliance with Rule 60,"
— J&K High Court

Legal Representation:

• M. Amin Khan, Advocate for the Petitioner
• Javid Ahmad Parray, Advocate for the Respondents

Case-Title: Saja Begum vs Financial Commissioner Revenue J&K Govt.& Ors, 2025

In a significant judgment, the Supreme Court recently acquitted a college student named Vaibhav in a 2010 murder case in which his friend Mangesh was killed. The verdict came after the court found that the prosecution failed to produce a full and convincing chain of circumstantial evidence to justify the conviction.

Read also: Supreme Court: Builder not liable to pay interest on homebuyer's bank loan for delay in possession of flat

The case involved a tragic incident in which Mangesh, a first-year student at Bagla Homoeopathy Medical College, was found dead after Vaibhav went home. The prosecution had claimed that Vaibhav shot Mangesh with his father's licensed service pistol. However, Vaibhav argued that Mangesh accidentally shot himself while handling the weapon.

"The suspicion must have been substantiated by undisputed, credible, clear, consistent and reliable circumstantial evidence, which does not leave the possibility of any other theory." - Supreme Court

The trial and the High Court had convicted Vaibhav under Sections 302 and 201 read with Section 34 of the IPC and also under the Arms Act. These courts relied heavily on Vaibhav's conduct after the incident—such as removing the body, cleaning the blood-stained floor and visiting Mangesh's house to inquire about his well-being.

Read also: Supreme Court quashes 498A IPC case against husband and in-laws on grounds of vague allegations, warns against misuse

However, the Supreme Court bench of Justices BV Nagarathna and SC Sharma rejected these convictions, and said that such conduct after the incident cannot in itself prove guilt. The court clarified that the prosecution did not prove a crucial fact—who pulled the trigger.

"The inability of the appellant to explain certain circumstances cannot be made a ground to absolve the prosecution of its primary onus." - Supreme Court

The court emphasised that the conduct, though questionable and legally punishable, may have been caused by panic. Vaibhav, a young student with no criminal record or motive, may have done so out of fear after witnessing the accidental shooting.

Read also: Kapil Sibal raises concern over delay in action on impeachment motion against Justice Shekhar Yadav

"That his act of removing the body and hiding the belongings was a result of his fear of his father—it is quite natural." - Supreme Court

Moreover, forensic evidence supported Vaibhav's version. The trajectory of the bullet and the injury pattern matched with accidental firing, and no concrete motive was established by the prosecution.

"The complete absence of motive, though not conclusive, is a relevant factor which weighs in favour of the accused." - Supreme Court

While acquitting Vaibhav of charges under Section 302 of the IPC and the Arms Act, the court upheld his conviction under Section 201 of the IPC for causing disappearance of evidence. However, it reduced his sentence to the period already served.

Case Title: VAIBHAV VERSUS THE STATE OF MAHARASHTRA

Appearance:

For Appellant(s) Mr. Vipin Sanghi, Sr. Adv. Mr. Satyajit A. Desai, Adv. Mr. Siddharth Gautam, Adv. Mr. Ananya Thapliyal, Adv. Mr. Abhinav K. Mutyalwar, Adv. Mr. Sachin Singh, Adv. Ms. Anagha S. Desai, AOR

For Respondent(s) Mr. Aaditya Aniruddha Pande, AOR Mr. Siddharth Dharmadhikari, Adv. Mr. Bharat Bagla, Adv. Mr. Sourav Singh, Adv. Mr. Aditya Krishna, Adv. Mr. Adarsh Dubey, Adv.