Mere Recovery Of Blood Stained Weapon With Blood Group Of Victim Not Enough For Conviction In Murder Case: SC

The Supreme Court has reiterated that the mere recovery of a blood-stained weapon, even if it matches the blood group of the victim, is insufficient to establish a charge of murder.

A bench comprising Justices Sandeep Mehta and Prasanna B Varale dismissed the Rajasthan government’s appeal challenging a 2015 judgment of the Rajasthan High Court that had acquitted one Hanuman of murder charges. The High Court had overturned a 2008 conviction by the Additional Sessions Judge, Fast Track Court, Kota, which sentenced the respondent to life imprisonment for the alleged murder of Chotu Lal.

The case dates back to the intervening night of March 1–2, 2007, when Chotu Lal was found murdered. The initial FIR was lodged against unknown assailants, but Hanuman was later implicated based on suspicion and circumstantial evidence. The prosecution claimed the accused harboured an "evil eye" on the victim’s wife and pointed to the recovery of the alleged weapon of offence, which bore blood stains matching the victim’s blood group (B+ve), according to the FSL report.

However, the High Court found the prosecution’s case inadequate, holding that the circumstances relied upon failed to form a complete and unbroken chain necessary to prove guilt beyond reasonable doubt in a case based entirely on circumstantial evidence.

Agreeing with the High Court’s reasoning, the Supreme Court noted, “We find that 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.”

While the state had placed heavy reliance on the forensic report, 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 bench referred to its own 2024 judgment in Raja Naykar v. State of Chhattisgarh, which clarified that recovery of a blood-stained weapon, even bearing the same blood group as the victim, cannot by itself establish the offence of murder.

The Court also found the prosecution’s theory of motive to be weak and inconsistent. “In the present case, 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,” the Court concluded.

Finding no infirmity in the High Court's acquittal, the Supreme Court dismissed the appeal as lacking merit.

Case Title: State of Rajasthan Vs Hanuman