Mere Recovery Of Blood-Stained Weapon Not Enough To Prove Murder: Supreme Court Reiterates

Emphasizing the need for a complete and convincing chain of circumstantial evidence, the Court ruled that such limited forensic findings, without corroborating proof, cannot alone sustain a conviction for murder.

The Bench of Justice Sandeep Mehta and Justice Prasanna B. Varale dismissed an appeal filed by the State of Rajasthan challenging the acquittal of a man earlier convicted for murder, ruling that the prosecution failed to establish a complete chain of circumstantial evidence to sustain the charge of murder under Section 302 of the Indian Penal Code.

The Court affirmed the Rajasthan High Court’s decision dated May 15, 2015, which had set aside the conviction and life sentence imposed by the Additional Sessions Judge, Fast Track Court, Kota, in Sessions Case No. 63 of 2007.

Facts of the Case

The case pertained to the alleged murder of one Chotu Lal, whose body was discovered on the night of March 1–2, 2007. An FIR was registered against unknown assailants, and the respondent was later implicated on the basis of suspicion and circumstantial evidence.

The Trial Court had convicted the accused relying on the alleged motive; namely, that the accused had an "evil eye" on the deceased’s wife, and on the recovery of a blood-stained weapon, which was confirmed by the Forensic Science Laboratory (FSL) to have the same blood group (B+ve) as that of the deceased.

However, on Appeal, the Rajasthan High Court found the prosecution’s case to be lacking, holding that the evidence did not form a complete and unbroken chain necessary for a conviction based solely on circumstantial evidence. The High Court accordingly acquitted the respondent.

The State of Rajasthan then approached the Supreme Court, arguing that the High Court had failed to properly appreciate the FSL report and other material on record.

Court's Observations

Rejecting the Appeal, the Supreme Court observed, “Even if the FSL report is taken into account, other than the fact that the weapon recovered at the instance of the accused tested positive for the same blood group as the deceased, nothing much turns on the said report.”

Referring to its earlier judgment in Raja Naykar v. State of Chhattisgarh [(2024) 3 SCC 481], the Court reiterated that “mere recovery of a blood-stained weapon, even bearing the same blood group of the victim, would not be sufficient to prove the charge of murder.”

On the alleged motive, the Court noted that the prosecution’s evidence was vague and inconsistent. It emphasized that, in an Appeal against acquittal, interference is only warranted if the view taken by the High Court is wholly unsustainable and no other conclusion is possible based on the evidence.

“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 bench stated.

Concluding that the High Court’s judgment did not suffer from any legal infirmity, the Supreme Court dismissed the appeal as being devoid of merit. All pending applications were disposed of accordingly.