'A' is tried for murder of 'B'. Whether the facts that 'C' knew that 'A' has murdered 'B' and that 'C' has tried to extort money from 'A' by threatening to make his knowledge public, are relevant? Answer with reference to legal provisions.

The Illustration as Stated in the Law

The exact words of Illustration (a) to Section 8 of the IEA (now Illustration (a) to Section 6 of the BSA) provide:

"A is tried for the murder of B. The facts that A murdered C, that B knew that A had murdered C, and that B had tried to extort money from A by threatening to make his knowledge public, are relevant."

In the question before us, the scenario is slightly modified — it is C (not B) who possesses the dangerous knowledge and attempts extortion against A (not against B himself). But the principle is precisely the same: the extortion attempt by C against A is the very motive that propels A to murder B. The legal reasoning is unchanged and the answer under the governing provision is the same.

The Legal Foundation: Section 8 IEA / Section 6 BSA

Section 8 of the IEA (corresponding to Section 6 of the BSA) opens with the declaration: "Any fact is relevant which shows or constitutes a motive or preparation for any fact in issue or relevant fact."

The fact in issue in the trial of A for the murder of B is whether A committed the murder. To sustain a conviction, the prosecution must establish not just the act of killing but the criminal intention that animated it. In a world where courts see only the surface of events, the law of evidence opens a window into the psychology of the accused — why he did what he did. Section 8 IEA / Section 6 BSA is that window.

Motive, as the courts have consistently defined it, is the emotion supposed to have led to the act — the moving power which impels action for a definite result. It is the psychological engine behind the deed. As one Massachusetts court put it, in an observation quoted approvingly in Indian jurisprudence, "The ordinary feelings, passions and propensities under which parties act are facts known by observation and experience, and they are so uniform in their operation that a conclusion may be safely drawn that, if a party acts in a particular manner, he does so under the influence of a particular motive."

Unpacking the Facts: Why Are They Relevant?

The First Fact: That A Murdered C

The fact that A earlier murdered C is, in isolation, a fact about a separate crime. At first glance, one might wonder why it should be admissible in the trial of A for the murder of B. The answer lies in the logical chain that the law recognises. The fact that A murdered C is not relevant to show that A is a murderer by nature — that would be impermissible character evidence. It is relevant because it is the foundation — the first link — in the causal chain that explains why A had a reason to kill B.

Without this fact, the rest of the chain collapses. It is the source from which B's leverage flows, and therefore it is the ultimate origin of A's motive. Section 8 IEA / Section 6 BSA makes it relevant not as evidence of bad character but as evidence of the specific motive for the specific murder with which A is charged.

The Second Fact: That B Knew of A's Murder of C

The knowledge in B's possession is the crucial connecting fact. It transforms B from a stranger into a person who holds power over A — the power of damning information. This knowledge is the source of the blackmail. Without it, B cannot extort and A has no reason to silence B. This fact is the pivot of the motive — it explains the precise relationship between A and B that gave A a compelling reason to want B dead.

In the ordinary course of criminal investigation, the prosecution seeks to answer the question: why would A want to kill B? If B were a stranger, a business rival, or a random person, the prosecution would struggle to supply a motive. The fact of B's knowledge answers that question definitively and with surgical precision.

The Third Fact: That B Tried to Extort A by Threatening to Expose Him

This fact is the motive itself — stated in its most concrete form. B threatens to expose A for the murder of C unless A pays money. This is extortion under the criminal law. But evidentially, it is something more — it is the direct, proximate cause of A's motive to kill B. A murdered B not out of a generalised hostility, but out of a very specific and desperate need to silence a blackmailer who could send him to the gallows.

The courts have held that previous threats, previous altercations, and previous litigation between parties are all admissible to show motive. In State of Uttar Pradesh v. Babu Ram (AIR 2000 SC 1735), the Supreme Court observed that the accused's demand and the deceased's resistance to it created a direct motive for murder — and that false explanations by the accused regarding motive are themselves relevant. The principle is the same here, only more vivid.

Section 14 IEA / Section 12 BSA: State of Mind

The relevancy of these facts is not limited to Section 8 alone. Section 14 of the IEA (Section 12 of the BSA) makes relevant any fact that shows the existence of a state of mind such as ill-will, intention, or knowledge towards a particular person, when the existence of that state of mind is in issue or relevant. The fact that B was blackmailing A — threatening to destroy him — establishes that A harboured a powerful ill-will directed specifically at B. This is not a general disposition but a particular, intense hostility born of a concrete situation. Illustration (e) to Section 14 IEA (Section 12 BSA) is instructive in this regard: "The fact of previous publications by A respecting B, showing ill-will on the part of A towards B, is relevant as proving A's intention to harm B's reputation." The principle applies with equal force to the illustration under discussion — the extortion attempt by B against A is evidence of the specific ill-will, the specific fear, and the specific intention that led A to commit the murder.

The Principle of Motive in Circumstantial Cases

The significance of these facts is particularly pronounced when the prosecution case rests on circumstantial evidence. The courts have repeatedly held that in a purely circumstantial case, motive assumes critical importance as one of the circumstances that must form a complete and unbroken chain pointing to the guilt of the accused. The Supreme Court articulated this in Surajdeo Mahto v. State of Bihar (AIR 2021 SC 3642), holding that "if motive attributed to an accused is proved, the probability of the crime being committed by the said accused is intensified."

At the same time, the law insists that motive, however strong, cannot take the place of proof. The Supreme Court in State of Punjab v. Sucha Singh (AIR 2003 SC 1471) held that "motive, however strong, cannot take the place of proof." The presence of a powerful motive intensifies the suspicion and strengthens an otherwise acceptable chain of circumstantial evidence, but it cannot by itself ground a conviction. The prosecution must still establish the act beyond reasonable doubt through the cumulative force of all the circumstances.

The Deeper Logic: Why This Matters to the Court

A murder trial, especially one without direct eyewitness testimony, is like assembling a puzzle. The fact in issue — whether A killed B — is often incapable of direct proof. The law of evidence permits the court to look at the entire landscape of the relationship between A and B, the history that precedes the killing, and the circumstances that would make the act explicable in human terms. The three facts in the illustration collectively answer the most important question a criminal court must ask: why would A want to kill B?

The answer is devastating in its clarity — A had murdered C, B knew it, and B was using that knowledge to bleed A of money. The logical inference that such a person, trapped in a blackmail scheme, might resort to eliminating the blackmailer is one that common human experience readily supports. This is precisely what the law means when it says that motive facts assist the court in reaching a conclusion on the matter in controversy. The relevancy arises because, if the court believes these facts to exist, they directly assist it in deciding whether A committed the murder.

Summary of Relevancy

The three facts are relevant on the following distinct grounds, which overlap and reinforce each other: