Supreme Court: Mere Recovery of Weapon with Victim’s Blood Group Insufficient for Murder Conviction
New Delhi, June 27, 2025 – In a landmark judgment reinforcing the high threshold required for murder convictions, the Supreme Court has ruled that the mere recovery of a blood-stained weapon matching the victim’s blood group does not suffice to establish guilt beyond reasonable doubt. The accused was acquitted after the Court found the prosecution's evidence lacking.
A two-judge bench — Justice Sandeep Mehta and Justice Prasanna B. Varale — upheld the judgment of the Rajasthan High Court, which had overturned a life sentence imposed by the trial court. The apex court dismissed the State of Rajasthan’s appeal, observing that the forensic match of blood group (B +ve) on the knife, without corroboration, cannot form the basis for a murder conviction.
Facts of the Case
The incident occurred on the night of March 1–2, 2007, in Rajasthan, involving the murder of a man named Chotu Lal. The victim was found dead, and an FIR was registered against unknown persons. The accused—later implicated—was allegedly jealous of the victim’s wife, which the prosecution presented as motive.
During the investigation, authorities recovered a knife from the accused. A forensic test confirmed the presence of blood belonging to the B +ve group—the same as the victim’s. Based on this, the trial court convicted the accused under Section 302 IPC, sentencing him to life imprisonment and a fine on December 10, 2008 .
High Court and Supreme Court’s Analysis
The Rajasthan High Court, in its May 15, 2015, judgment, acquitted the accused. It held that the prosecution had not established a complete chain of circumstances necessary for conviction based exclusively on circumstantial evidence.
Upholding this view, the Supreme Court noted that except for the knife bearing the victim’s blood group, "nothing much turns on the said report." The Court emphasized that in the absence of direct evidence—such as eyewitness testimony or incontrovertible linkage—the forensic finding remains weak.
Key Legal Principles Highlighted
-
Blood Group Evidence Is Not DefinitiveThe Court referenced its earlier judgment in Raja Naykar v. State of Chhattisgarh (2024), where it held that recovery of a blood-stained weapon—even if matching the victim’s blood group—cannot by itself warrant conviction.
-
Circumstantial Evidence Requires Full ChainThe bench reiterated the golden rule from Sharad Birdhichand Sarda v. State of Maharashtra—every link in the chain must be complete, ruling out alternative hypotheses, before guilt can be inferred.
-
Benefit of Doubt Must Prevail“Suspicion, however grave, cannot replace proof,” stated the Court. The evidence in this case failed to eliminate reasonable doubt regarding the accused’s guilt.
Investigation Lapses and Inconclusive Motive
The Supreme Court observed that the prosecution’s narrative was marred by inconsistencies:
-
The accused’s motive, based on alleged attraction to the victim’s wife, was speculative and lacked verification.
-
Crucially, there was no eyewitness testimony or direct evidence placing the accused at the scene during or immediately after the murder—a fatal flaw in relying on the forensic match
Thus, the Court found that the inference of guilt was not the "only possible conclusion" from the evidence presented.
Final Judgment
The Supreme Court concurred with the High Court’s verdict, acquitting the accused and upholding his right to the benefit of doubt. It held:
“Law is well settled by a catena of decisions … that in an appeal against acquittal, interference can only be made if the only possible view based on the evidence points to the guilt of the accused and rules out his innocence.”
Finding the prosecution had failed to meet this stringent standard, the apex court dismissed the State’s appeal (Criminal Appeal No. 631 of 2017, State of Rajasthan v. Hanuman.
Reactions and Implications
Legal experts have hailed the judgment as a reaffirmation of criminal jurisprudence that forensic evidence alone cannot supplant the principle of reasonable doubt. It underscores the necessity for robust investigation practices and the collection of corroborative evidence—particularly in capital cases.
This ruling will likely influence future criminal trials, especially those heavily reliant on forensic matches. It serves as a reminder to investigators and prosecutors alike that a conviction must be founded on a coherent, comprehensive case—not on isolated scientific findings.
