Source: Supreme Court 

Why in News? 

A Division Bench of comprising Justice Sandeep Mehta and Justice Prasanna B. Varale recently dismissed the appeal filed by the State of Rajasthan challenging the acquittal of the respondent (Hanuman).  

• The Court affirmed the Rajasthan High Court’s decision, which had set aside the respondent’s conviction and life sentence imposed by the Trial Court and held that Mere recovery of weapon with victim’s blood group not sufficient for conviction under Section 302 of the Indian Penal Code, 1860 (Section 103 of BNS). 
• The Supreme Court held this in the case of State of Rajasthan v. Hanuman (2025) 

What is the Background of State of Rajasthan v. Hanuman (2025) Case? 

• The incident pertains to the murder of one Chotu Lal, which occurred on the intervening night of 1 and 2 March, 2007.  
• The FIR was lodged against unknown persons. The respondent was later implicated on the basis of circumstantial evidence and suspicion. The prosecution's case relied on: 
  • The alleged motive that the accused had an evil eye on the deceased's wife; 
  • Recovery of a blood-stained weapon from the accused; 
  • FSL report confirming the blood group on the weapon as B+ve, the same as the deceased’s. 
  • The Trial Court convicted the respondent on 10th December 2008 under Section 302 IPC and sentenced him to life imprisonment with a fine of ₹100. 
  • In appeal, the Rajasthan High Court, vide judgment dated 15th May 2015, acquitted the respondent holding that the prosecution failed to establish the chain of circumstances required in a case based on circumstantial evidence. 

What were the Court’s Observations? 

• The Supreme Court found no merit in the State’s appeal. While the State contended that the High Court overlooked the FSL report, the Supreme Court observed: 
• “Even if the FSL report is taken into account, the only finding is that the weapon bore blood of the same group as the deceased (B+ve). That alone is not sufficient to convict.” 
• The Court relied upon its previous decision in Raja Naykar v. State of Chhattisgarh, (2024) 3 SCC 481, where it was held that: 
  • “Mere recovery of a blood-stained weapon even bearing the same blood group as that of the victim is not enough to sustain a conviction for murder.” 
• Further, the Court noted: 
  • The motive was vague and not conclusively established. 
  • The chain of circumstances was incomplete, and the prosecution failed to lead to clinching evidence that would rule out the respondent’s innocence. 
• The Bench reaffirmed that interference with acquittal is permissible only when the only possible view based on evidence is the guilt of the accused. In this case, the view taken by the High Court—i.e., the innocence of the accused—was held to be a plausible and the only possible view. 
• This ruling underscores that forensic evidence, such as FSL reports confirming matching blood groups, must be corroborated with other substantive evidence. 
• Circumstantial evidence must point conclusively to guilt, and absence of such clinching evidence entitles the accused to acquittal.  
• The Supreme Court’s ruling affirms the primacy of due process and benefit of doubt in criminal jurisprudence. 

What is the Law on Circumstantial Evidence? 

About:  

• Circumstantial evidence refers to indirect evidence that implies the commission of a crime but does not directly prove it.  
• The legal standard is that “All links in the chain of circumstances must be so complete that they unerringly point towards the guilt of the accused and rule out any hypothesis of innocence.” 

Five Golden Principles 

• It is well-settled in Sharad Birdhichand Sarda v. State of Maharashtra (1984), where the Court laid down the five golden principles, also known as the "Panchsheel," for reliance on circumstantial evidence: 
  • Circumstances must be fully established. 
  • The facts so established should be consistent only with the hypothesis of the guilt of the accused. 
  • The circumstances should be of a conclusive nature. 
  • They should exclude every possible hypothesis except the one to be proved. 
  • There must be a complete chain of evidence that points to the guilt of the accused. 

Difference Between Direct & Circumstantial Evidence: 

Landmark Judgements: 

• Anwar Ali v. State of Himachal Pradesh (2020): 
  • The Supreme Court in this case observed the principles laid down in various judgments regarding motive as a circumstance for conviction.  
  • The Court observed that in the case of Suresh Chandra Bahri v. State of Bihar (1995) it was held that if motive is proved that would provide a link in the chain of circumstances of evidence, but the absence of motive cannot be a ground to reject the prosecution case.  
    • At the same time in Babu v. State of Kerela (2010), the Court held that motive in a case depending on circumstantial evidence is a factor that weighs in favour of the accused. 
• Nagendra Shah v. State of Bihar (2021): 
  • The Supreme Court reinforced that, in cases resting on circumstantial evidence, an accused's failure to provide a reasonable explanation as required by Section 106 of IEA could serve as an additional link in the chain of circumstances. 
• Dilip Sariwan v. State of Chhattisgarh (2023): 
  • The Chhattisgarh High Court upheld murder convictions based heavily on circumstantial evidence tied to an extramarital affair, significance of Section 27 of the Indian Evidence Act,1872. The Court observed that in such cases, the prosecution must prove every link in the chain of circumstances beyond reasonable doubt, leaving no room for innocence.   
• Balvir Singh v. State of Uttarakhand (2023): 
  • In this case it was held that to convict the husband and his relatives there must be a full-fledged trial that is to be conducted, and the court cannot take help of the provisions of section 106 IEA for the same.