The Supreme Court of India has reaffirmed that mere recovery of a blood-stained weapon matching the victim's blood group alone does not justify conviction for murder. The observation was made while dismissing an appeal by the State of Rajasthan challenging a High Court order that acquitted a murder accused.
A division bench of Justice Sandeep Mehta and Justice Prasanna B. Varale upheld the Rajasthan High Court's May 15, 2015 judgment that reversed the trial court's conviction and sentence of life imprisonment against the accused.
The Supreme Court said, "Even if the FSL report is considered, apart from the fact that the blood group of the weapon recovered from the accused was the same as that of the deceased (B+V), no other connection can be established."
Read also: Supreme Court to Hear Plea Against Maratha Reservation in July
The case relates to the murder of Chhotu Lal, which took place between the night of March 1 and 2, 2007. Initially, an FIR was lodged against unknown persons. Later, the accused was made an accused on the basis of circumstantial evidence and suspicion.
The trial court had convicted the accused under Section 302 IPC on December 10, 2008 and sentenced him to life imprisonment with a fine of ₹100.
The prosecution had cited two main evidences:
- The alleged motive, which claimed that the accused had an evil eye on the wife of the deceased.
- The recovery of a weapon from the accused and a forensic report which showed that the blood on the weapon matched the blood group of the deceased.
Read also: NEET-PG 2024: Petition in Supreme Court Against Conversion of Chandigarh UT Quota to All India
However, the Rajasthan High Court held that the prosecution failed to prove the full chain of circumstantial evidence that could clearly point to the guilt of the accused and hence acquitted him.
When the matter reached the Supreme Court, it too found the prosecution evidence insufficient. The Court held that even if the High Court had ignored the FSL report, it did not have much bearing on the final outcome because:
“The FSL report only establishes the presence of the same blood group but does not by itself prove the guilt of the accused.”
The Supreme Court also cited its earlier judgment in Raja Naikar v. State of Chhattisgarh [(2024) 3 SCC 481], which established that recovery of a weapon bearing blood stains matching the blood group of the victim is not sufficient to substantiate the charge of murder.
Read also: Supreme Court Refuses to Grant Bail to PFI Leader AS Ismail on Medical Grounds, Seeks Report on
The Court observed “The law is well settled by catena of judgments of this Court that an appeal against acquittal can be interfered with only if the only possible view on the face of evidence points to the guilt of the accused and disproves his innocence.”
Concluding that the prosecution did not produce any conclusive evidence, the Court held that the High Court’s judgment of acquittal was the only possible view in the case.
Therefore, finding no legal error in the High Court’s judgment, the Supreme Court dismissed the appeal.
Case Title – State of Rajasthan v. Hanuman
Case No. – Criminal Appeal No. 631 of 2017
