Supreme Court: Mere Recovery of Blood-Stained Weapon Matching Victim’s Blood Group Not Sufficient to Prove Murder

The Supreme Court has rejected an appeal by the State of Rajasthan challenging the acquittal of a man previously convicted for murder. Supreme Court said that mere recovery of blood-stained weapon matching victim’s blood group not sufficient to prove murder in the absence of a full chain of circumstantial evidence.

Case Background

The case involves the murder of Chotu Lal on the night between March 1 and 2, 2007. Initially registered as a case against unidentified persons (FIR No. 37/2007), suspicion later fell on Hanuman, the respondent. The prosecution suggested a motive based on alleged inappropriate interest in the deceased's wife and presented circumstantial evidence including the discovery of a weapon said to be stained with the victim’s blood.

An FSL report indicated the blood on the weapon was of the same group (B+ve) as the victim. Based on this, the trial court found the respondent guilty under Section 302 of the IPC and sentenced him to life imprisonment with a nominal fine.

High Court's Intervention

Hanuman appealed his conviction, and on May 15, 2015, the Rajasthan High Court overturned the verdict, citing gaps in the prosecution’s case. The High Court concluded that the circumstantial evidence was insufficient to meet the threshold required for a conviction.

Supreme Court’s Rationale

Upon review, the Supreme Court Bench of Justices Sandeep Mehta and Prasanna B. Varale found no legal fault in the High Court’s reasoning. The Bench observed that neither the alleged motive nor the blood-stained weapon constituted a conclusive chain of evidence to prove guilt beyond reasonable doubt.

The Court remarked that even considering the FSL results, the only evidence tying the accused to the crime was the blood group match—something not unique or uncommon. As per established precedent, including Raja Naykar v. State of Chhattisgarh (2024), such evidence alone cannot uphold a murder conviction.

The Court also noted that the alleged motive lacked clarity and consistency, further weakening the prosecution's case.

Conclusion

Reiterating the principle that appellate courts should not disturb acquittals unless the guilt is the only reasonable conclusion, the Supreme Court affirmed the High Court’s view and dismissed the appeal. Any related pending applications were also disposed of.

Case Title: [State of Rajasthan vs Hanuman Criminal Appeal No.: 631 of 2017]