Mere Recovery of Weapon with Victim's Blood Group Not Enough for Murder Conviction: Supreme Court

In a significant ruling reinforcing the stringent standards for conviction in murder cases based on circumstantial evidence, the Supreme Court of India has held that the mere recovery of a blood-stained weapon, even if it matches the victim's blood group, is not sufficient to establish guilt beyond reasonable doubt.

The judgment, delivered by a bench of Justices Sandeep Mehta and Prasanna B. Varale on June 27, 2025, came in the case of State of Rajasthan v. Hanuman (Criminal Appeal No. 631 of 2017). The apex court upheld the acquittal of the accused, Hanuman, by the Rajasthan High Court, which had overturned a trial court's conviction.

The case originated from the alleged murder of one Chotu Lal in 2007. The prosecution's case against Hanuman primarily rested on circumstantial evidence, including an alleged motive (that the accused had an "evil eye" on the deceased's wife), the recovery of a blood-stained weapon at his instance, and a Forensic Science Laboratory (FSL) report indicating that the blood on the weapon belonged to blood group B+ve, which matched the victim's blood group.

However, the Supreme Court affirmed that while the FSL report showed a match, "nothing much turns on the said report" because blood group matching is a class evidence and cannot establish individual identity. The Court stressed that multiple individuals share the same blood group, limiting its probative value without further corroborating circumstances. The alleged motive was also deemed "very vague and vacillating" by the Court.

Citing its own earlier precedent from Raja Naykar v. State of Chhattisgarh (2024) 3 SCC 481, the bench reiterated that the mere recovery of a blood-stained weapon, even bearing the same blood group as the victim, is insufficient alone to prove a murder charge.

The judgment underscores that in cases based solely on circumstantial evidence, the prosecution must prove every link in the chain of circumstances, forming a complete and unbroken chain that points unequivocally to the guilt of the accused. The Court emphasized that convictions must be founded on proof beyond reasonable doubt, not on suspicion or incomplete evidence. Furthermore, in appeals against acquittal, interference is warranted only if the evidence leads to guilt as the sole possible conclusion, ruling out innocence.