Supreme Court acquits man convicted of matricide, finds prosecution failed to prove homicide beyond doubt

Case Name: Nilesh Baburao Gitte v. State of Maharashtra
Date of Judgment: October 07, 2025
Citation: 2025 INSC 1191, Criminal Appeal No. 1471 of 2013
Bench: Hon’ble Mr. Justice K.V. Viswanathan and Hon’ble Mr. Justice K. Vinod Chandran

Held: The Supreme Court allowed the appeal of Nilesh Baburao Gitte, who had been convicted of murdering his mother, and acquitted him of all charges. The Court held that the prosecution case, resting entirely on circumstantial evidence, failed to satisfy the strict standards laid down in Sharad Birdhichand Sarda v. State of Maharashtra. Serious doubts existed regarding whether the death was homicidal at all, with medical testimony indicating hanging could not be ruled out. The Court also found the recoveries unreliable, the alleged motive unproven, and key witnesses tainted by enmity.

Summary: The appellant was convicted under Section 302 IPC for murdering his mother, Sunanda, and sentenced to life imprisonment. The trial court had relied on circumstantial evidence such as hurried cremation attempts, discovery of rope and pipe, forensic reports, and alleged motive of property gain. The Bombay High Court, Aurangabad Bench, upheld the conviction in 2013.

Before the Supreme Court, the appellant argued that medical evidence was inconclusive, as the absence of ligature marks around the neck suggested hanging rather than strangulation. A hospital certificate showing the deceased suffered from schizophrenia further supported suicide as a possibility. The defence also attacked the credibility of the recovery witnesses and pointed out contradictions, delays in recording statements, and enmity of a key relative (PW-3) who allegedly had property disputes. The State relied on the conduct of the appellant, his proximity to the deceased, and forensic findings to press for conviction.

The Supreme Court analysed the medical evidence, finding that the postmortem report did not conclusively prove homicide, and that alternative explanations were plausible. It noted that the prosecution failed to investigate crucial leads, including the attempted cremation scene witnessed by police officers. The Court disbelieved the recovery evidence, found the alleged motive unconvincing, and emphasized that suspicion cannot replace proof in cases of circumstantial evidence.

Decision: The Supreme Court held that the prosecution had not established a complete and conclusive chain of circumstances pointing only to the appellant’s guilt. With doubts about the cause of death, unreliable recovery evidence, absence of proven motive, and the acquittal of a co-accused on the same evidence, the Court concluded that the conviction was unsafe. It therefore set aside the Bombay High Court’s 2013 judgment, acquitted the appellant of all charges, and discharged his bail bonds.