SUPREME COURT: WEAPON RECOVERY WITH VICTIM’S BLOOD INSUFFICIENT TO PROVE MURDER:

The Supreme Court recently dismissed an appeal filed by the State of Rajasthan challenging the acquittal of a man accused of murder. The Court observed that the mere recovery of a blood-stained weapon matching the victim’s blood group is not sufficient to sustain a conviction for murder. A bench comprising Justice Sandeep Mehta and Justice Prasanna B. Varale upheld the Rajasthan High Court’s judgment dated May 15, 2015, which had set aside the trial court’s conviction and life sentence imposed on the accused.

The case involved the murder of one Chotu Lal, which occurred during the night of March 1–2, 2007. An FIR was initially registered against unknown persons, but the respondent was later implicated based on suspicion and circumstantial evidence. The trial court, on December 10, 2008, had found the respondent guilty under Section 302 of the Indian Penal Code (IPC), sentencing him to life imprisonment and a fine of Rs. 100. The prosecution primarily relied on two elements: the alleged motive, stating that the respondent had an evil eye on the deceased's wife—and the recovery of a weapon that bore blood stains matching the victim’s blood group (B+ve), as confirmed by a forensic science laboratory (FSL) report.

Upon appeal, the Rajasthan High Court found that the prosecution had failed to establish a complete and conclusive chain of circumstances that would justify a conviction in a case based solely on circumstantial evidence. As a result, the respondent was acquitted. The State then approached the Supreme Court, seeking to overturn this acquittal.

The Supreme Court concurred with the High Court's reasoning, emphasizing that the prosecution had not provided enough incriminating material to warrant a conviction. While acknowledging the State’s argument that the High Court had overlooked the FSL report, the Supreme Court clarified that even when the report was taken into account, it merely established the presence of the deceased's blood group on the weapon. This, the Court held, was not enough to conclusively prove guilt. Referring to its previous judgment in Raja Naykar v. State of Chhattisgarh (2024) 3 SCC 481, the Court reiterated that recovery of a weapon with the same blood group as the victim does not, by itself, prove the charge of murder.

The bench also found the prosecution’s argument regarding motive to be vague and lacking in substantive support. It underscored that in appeals against acquittal, judicial interference is permissible only when the evidence on record leads to no other conclusion except the guilt of the accused, excluding any possibility of innocence. In this case, the Court found that the evidence fell short of that standard.

Concluding that the prosecution had failed to present conclusive or clinching evidence, the Supreme Court held that the view adopted by the High Court was not only reasonable but also the only one possible based on the evidence presented. Accordingly, the appeal filed by the State of Rajasthan was dismissed, and the acquittal of the accused was upheld.