In a landmark judgment, the Supreme Court held that mere recovery of a weapon is not enough without forensic linkage, it cannot prove guilt. This judgment reinforces the need for scientific evidence in murder trials to uphold the standard of proof beyond doubt.
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NEW DELHI: On 19 June 2025, in a landmark judgment, the Hon’ble Supreme Court of India reiterated a essential principle of criminal jurisprudence, mere recovery of a weapon is not sufficient to establish guilt in a murder case unless it is conclusively linked to the crime through forensic or medical evidence.
The Court emphasized that the standard of proof beyond reasonable doubt must be strictly upheld, especially in cases involving serious charges like murder. This ruling not only led to the acquittal of the accused but also served as a strong reminder to investigative authorities about the importance of scientific corroboration in criminal trials.
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Background of the Case
The case arises from a murder investigation in which the police accused the appellant of shooting the deceased Chotu Lal. During the investigation, the accused allegedly led the police to the recovery of a pistol under Section 27 of the Indian Evidence Act.
The prosecution relied heavily on the recovery of weapon and the FSL (Forensic Science Laboratory) report that was indicating that the blood group on the weapon matched with the blood group of the deceased, i.e., B+ve.
However, there were no eyewitnesses to the incident, and the case lacked direct evidence. Critically, the recovered weapon was not subjected to forensic analysis, nor there was any medical evidence to conclusively show that the injuries on the deceased matched the weapon in question.
Despite the seriousness of the charge, the investigation failed to build a coherent and scientifically supported case. The trial court convicted the accused based on circumstantial evidence, but the matter was taken up on appeal, eventually reaching the Supreme Court.
Issues Before the Court
Whether the prosecution successfully established a complete chain of circumstances to convict the accused under Section 302 IPC based solely on circumstantial evidence.
Whether the recovery of a blood-stained weapon, allegedly at the instance of the accused, was sufficient to prove guilt in the absence of corroborative forensic or medical evidence.
Whether the High Court was justified in acquitting the accused by holding that the chain of circumstantial evidence was incomplete.
Observation of the Court
The Court said,
“We find that the incriminating circumstances relied upon by the prosecution, i.e., the motive and 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.”
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The Court held that the prosecution failed to establish a complete and coherent chain of circumstantial evidence. While motive and weapon recovery were presented, they did not conclusively prove the accused’s guilt beyond reasonable doubt.
Though the prosecution emphasized a FSL report which confirmed that the blood found on the weapon matched the deceased’s blood group (B+ve), this alone was insufficient. The Court stated that
“The presence of blood on a weapon is not conclusive unless it is clearly proven that it caused the fatal injuries.”
The Court relied to the case of Raja Naykar v. State of Chhattisgarh (2024) 3 SCC 481, which held that,
“Mere recovery of a blood-stained weapon, even bearing the victim’s blood group, is not enough to establish murder, unless the weapon is forensically linked to the cause of death.”
The Court reaffirmed that in criminal jurisprudence, the presumption of innocence prevails unless guilt is proven beyond doubt. the Court said,
“The appeal lacks merit and is dismissed.”
READ ORDER:
CASE TITLE: State of Rajasthan vs Hanuman, Criminal Appeal No. 631 of 2017
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