The Delhi High Court observed that proving motive is not essential to uphold a murder charge, noting that motive is not a critical element of an offence as many serious crimes often arise from trivial or insignificant reasons.
The Delhi High Court stated that establishing motive is not essential for upholding a murder charge.
A Division Bench, comprising Justices Subramonium Prasad and Vimal Kumar Yadav, noted that motive is not a critical component of an offense, as many serious crimes arise from trivial or inconsequential reasons.
The Court held,
“The proof of motive is not necessary to sustain a conviction on a murder charge when there is clear evidence that the person had been done to death by the accused. In other words, when the facts establishing the charge are clear it is immaterial that the motive has not been proved. The reason is that the motive of an act may be known to the perpetrator and to none other and the investigator may not have been able to collect any information in regard thereto,”
The judges further remarked that evidence of motive is often of secondary importance in such cases.
The Court emphasized,
“The mere fact that the accused had a motive to cause the death of the deceased is not a fact which will dispense with the proof of points that the accused had got a suitable immediate occasion for committing the crime and of actually committing it,”
These comments were made while affirming the conviction and life sentence of Mohd Nawab for the murder of a rickshaw puller named Giani in November 1998. One of the arguments raised in the appeal to the High Court was that the prosecution did not demonstrate any motive on Nawab’s part.
However, the Court dismissed this argument, affirming that Nawab’s guilt was established beyond a reasonable doubt.
It concluded,
“Consequently, the appeal fails and is hereby dismissed,”
Mohd Nawab was represented by advocates SK Sharma, Tejas Singh, Rahul Sharma, Yogender, and Saurabh Dagar, while Additional Public Prosecutor Aashneet Singh represented the State.
In simple legal terms, murder means when a person intentionally causes the death of another person. It is one of the most serious criminal offences under the Indian Penal Code (IPC), Section 300.
To prove someone guilty of a crime, the law generally requires two things:
- Actus Reus – the guilty act (the physical action or omission), and
- Mens Rea – the guilty mind (the intention, knowledge, or recklessness).
Mental Elements
The mental element shows what was going on in the person’s mind when the act was done whether they intended to break the law, knew the result, or were careless about the consequences.
- Intention: The person meant to cause the result (e.g., planning to kill someone).
- Knowledge: The person knew that their act would likely cause harm or death.
- Recklessness: The person ignored the risk of their act causing harm.
- Negligence: The person failed to take reasonable care, though not intending harm.
Case Title: Mohd Nawab v State NCT of Delhi
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