The Special Leave Petition (SLP (Crl.) No(s). 1977 of 2026) filed by Pooranmal (‘the appellant’) before the Supreme Court of India. The SLP was filed against the conviction awarded by the trial court in the criminal case involving murder charges and conviction under Section of 302/34 of Indian Penal Code 1860 (‘IPC’) [Ref. Sections 103 (1)/3(5) of the Bhartatiya Nyaya Sanhita, 2023 (‘BNS’)]. Subsequently, an appeal against conviction was rejected by the High Court of Rajasthan. This case involved multi fold issues before the Supreme Court of India while proceeding,
List of Issues:
The Supreme Court of India of India concluded this case on March 10th, 2026.
2.1. The murder crime took place overnight of March 2nd and 3rd, 2010 where Smt. Arun (‘the Victim’) was found murdered in her home. The victim was living with her husband and a son. Initial report was filed by the victim ’s husband Ladu Lal (‘the accused’) with Bijolia Police Station. The accused claimed he and his son were sleeping during the night and he got apprised that his room was locked from outside. The accused claimed he tried contacting the victim who was sleeping in another room but no response was received. The accused further tried calling his brother and Constable Shankar Singh posted at Bijolia Police Station. In mean time people living nearby were gathered. When the victim’s room was checked, she was found dead with serious injuries. The accused also claimed the cash of 4 Lakhs were missing. The FIR number 28 of 2010 was registered at the PS. Bijolia under Section 460 of the IPC (Ref. Section 331(8) of the BNS) against unknown persons.
2.2. During investigation, the Investigating Officer (‘IO’) found the accused Ladu Lal behaviour suspicious and further arrested on apprehension of his involvement in crime. The accused made confession and stated he was involved in the crime and additionally named the current appellant Pooranmal as his acquittance.
2.3. The co-accused Pooranmal was also arrested, during investigation below listed recoveries were made by IO,
• a blood-stained shirt
• a sum of Rs. 46,000/-
• the call records between accused and co-accused during same time on the day of incident
2.4. The IO filled the charge sheet before the trial court at Bhilwara, Rajasthan under Sections 302/34 and 201 of the IPC [Ref. Sections 103 (1) / 3(5) and 238 of the BNS]. During trial, the prosecution examined twenty-four witnesses and exhibited fifty-five documents along with seven articles to prove their case. The trial court concluded the proceeding and convicted the accused (Ladu Lal) and co-accused (the appellant-Pooranmal) on 8th February, 2012.
2.5. The trial court passed conviction for the offence punishable under Section 302 & Section 34 of the Indian Penal Code, 1860 [Ref. Section 103 (1) & Section 3(5) of the Bhartatiya Nyaya Sanhita, 2023] and were sentenced to undergo life imprisonment and fine of Rs. 5,000/-. Also, the accused were convicted for the offence punishable under Section 201 of the IPC [Ref. Section 238 of the BNS] and sentenced to undergo seven years rigorous imprisonment and fine of Rs. 5,000/-.
2.6. The appellant-Pooranmal filled appealed against conviction before Hon’ble High Court of Rajasthan – it was rejected. Hence the appellant-Pooranmal preferred this SLP before the Supreme Court of India.
3.1. The Learned Council on behalf of the appellant argued that the conviction was totally based on the circumstantial evidences and guesses. The prosecution case failed to establish the appellant’s involvement beyond reasonable doubt.
3.2. The Learned Council further claimed, the evidences produced before the trial count were neither sufficient nor credible,
• The blood-stained shirt which was claimed to be recovered from the co-accused.
• The electronic evidence involving call details between the accused and the co-accused were inadmissible in absence of the mandatory certificate under Section 65-B of the Indian Evidence Act, 1872 (‘IEA’) - [Ref. Section 63 of the BSA].
• The currency notes recovered were unable to establish any material link between accused and co-accused for money transaction which could prove the involvement of co-accused.
4.1. The prosecution submitted that the SLP of accused (Ladu Lal) was already rejected by the Supreme Court of India and there is no reason for consideration of this new SLP by the appellant who is co-accused.
4.2. The prosecution also claimed that the recovery of the blood-stained shirt and currency notes from appellant and the call detail records between both the accused were satisfactory to establish the appellant’s guilt in the crime.
4.3. The prosecution emphasized that the appellant was unable to prove any explanation/counter for the circumstantial evidence produced on record to prove his innocence in any way.
The Hon’ble Supreme Court of India evaluated all involved issues in this case as below,
5.1. The Leave can be granted?
→ Yes, the appellant claimed he was financially weak and he was able to submit the appeal with help of legal aid cell.
→ No, appeal cannot be rejected on this ground. One crime involving multiple accused persons, rights like bail, appeal remains independently for accused person. Role of individual accused and relevant Bona fide evidences remains base for considering such scenarios on case-to-case basis.
Hence the Supreme Court of India, granted leave in this SLP to co-accused.
5.2. The conviction of the appellant was on circumstantial evidence?
→ Yes, the Court concluded the conviction was on circumstantial evidence.
5.3. All evidence produced on record were sufficient for proving guilt of co-accused and beyond reasonable doubt?
→ Any person who committed a crime where his shirt with blood stains on it will be crucial evidence. No criminal will retain or keep such proof which could lead to prove his involvement in crime. The first attempt will be made to destroy the evidence. In this case, the blood strain shirt was recovered on 04th March 2010, appellant had sufficient time to destroy or simply wash it. Hence the prosecution theory did not add up effectively to consider the blood-stained shirt as evidence.
→ The prosecution backed the FSL blood report to establish the appellant involvement – the said report pointed to the victim’s blood group O Positive and that was matching with the blood-stains on the appellant shirt. The Court checked the prerequisite for considering such report admissible,
→ As per the malkhana register entries and the confrontation was done with prosecution witness. The IO submitted sealed evidence on 07th March 2010 to the Malkhana and the same was mentioned to be sent to FSL on 12th March 2010. But the Carrier Constable specifically stated the evidence was carried on 18th March 2010 which was contradictory. Hence, there was a grave discrepancy regarding the safe-keeping/chain of custody of the muddamal articles. The claim, FSL returned evidence on 15th March 2010, fails to conclude as there was no reason or ground mentioned for such return or even proved. This concludes the evidence was submitted to FSL on 18th March 2010. Considering all these, it breaches the unbroken chain of custody mandatorily required to prove the safe keeping of the muddamal articles. The Court gave reliance on Karandeep Sharma alias Razia alias Raju v. State of Uttarakhand1, in para 54 and para 55.
Considering the above details the Court concluded the FSL Report is not admissible evidence in this as serious doubts on chain of custody and timelines were raised.
→The established process for electronic evidence is available under the Section 65-B of the Indian Evidence Act, 1872. This provision clearly says: it requires a mandatory certificate under Section 65-B of the Indian Evidence Act, which is a prerequisite for admitting electronic evidence. The Court held that the call detail records were inadmissible due to the absence of said certificate. The Supreme Court refer the case Arjun Panditrao Khotkar v. Kailash Kushanrao Gorantyal4.
Considering all above details the Circumstantial Evidences were not sufficient to prove the guilt of appellant. The law governing cases resting on circumstantial evidence is no longer res integra. The Court referred to the principles laid down in the case of Sharad Birdhichand Sarda v. State of Maharashtra5. It concluded that the prosecution failed to establish a complete and clear chain of circumstances pointing unambiguously to the appellant’s guilt.
The Supreme Court of India set aside the conviction of the trial court. Acquitted the appellant-Pooranmal of all the charges. The Court concluded that the prosecution failed to prove the charges against the appellant beyond reasonable doubt and those were only on the basis of circumstantial evidence.
In this case of Pooranmal v. State of Rajasthan & Anr., the Hon’ble Supreme Court highlighted the crucial importance of established legal principles in cases based on circumstantial evidence. The Court explained that there should be a complete and unbroken chain of evidence. The mandatory compliance of procedural requirements for the admissibility of electronic evidence under Section 65-B of IPC shall be followed. The decision serves as a reminder of the fundamental principle that an accused must be proven guilty beyond reasonable doubt, and any breach in the chain of custody of evidence or procedural gaps can lead to acquittal.
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