The Supreme Court has dismissed the appeal filed by the State of Rajasthan challenging the acquittal of an accused in a murder case, holding that the recovery of a blood-stained weapon matching the victim’s blood group is not sufficient to establish guilt. The Court affirmed the Rajasthan High Court’s decision acquitting the accused due to lack of a complete chain of circumstantial evidence.
Background
The case pertains to the murder of Chotu Lal, which occurred on the intervening night of 1st and 2nd March, 2007. FIR No. 37 of 2007 was initially lodged against unknown persons. Subsequently, the respondent Hanuman was arraigned on the basis of suspicion and circumstantial evidence.
The prosecution alleged that the respondent had an evil eye on the deceased’s wife and presented this as the motive. The charge was further supported by the alleged recovery of the weapon of offence from the respondent and an FSL report stating that the blood group on the weapon (B+ve) matched that of the deceased.
The Trial Court (Additional Sessions Judge No. 1, Fast Track, Kota) convicted the respondent under Section 302 of the Indian Penal Code and sentenced him to life imprisonment along with a fine of ₹100.
High Court Judgment
The respondent challenged the conviction before the Rajasthan High Court, which allowed the appeal via judgment dated 15 May 2015 in Criminal Appeal No. 788 of 2009. The High Court found that the prosecution failed to prove the complete chain of circumstances necessary for conviction and acquitted the accused.
Supreme Court’s Analysis
Before the Supreme Court, the State of Rajasthan argued that the High Court had erred by not giving sufficient weight to the FSL report and the recovery of the blood-stained weapon. However, the Bench comprising Justice Sandeep Mehta and Justice Prasanna B. Varale found no merit in the appeal.
The Court noted:
“The incriminating circumstances relied upon by the prosecution, i.e., the motive and the recovery of the blood-stained weapon, even taken in conjunction, cannot constitute the complete chain of incriminating circumstances required to bring home the charges against the accused.”
On the FSL evidence, the Court observed:
“Even if the FSL report is taken into account, then also, other than the fact that the weapon recovered at the instance of the accused tested positive for the same blood group as that of the deceased (B+ve), nothing much turns on the said report.”
The judgment relied on the precedent laid down in Raja Naykar v. State of Chhattisgarh, (2024) 3 SCC 481, where it was held that mere recovery of a blood-stained weapon matching the victim’s blood group is not sufficient to establish the offence of murder.
Regarding the alleged motive, the Court observed that the evidence was “very vague and vacillating.”
The Court reiterated the well-established principle that appellate courts should not interfere with an acquittal unless the only possible view from the evidence is one of guilt:
“We are duly satisfied that the prosecution failed to lead clinching evidence to bring home the charges. The only possible view is the one taken by the High Court, i.e., the innocence of the accused.”
Decision
Finding no infirmity in the High Court’s acquittal, the Supreme Court held that the appeal lacked merit and dismissed it. All pending applications, if any, were also disposed of.
Case Title: State of Rajasthan vs Hanuman
Criminal Appeal No.: 631 of 2017
