Pooranmal (Appellant) Vs. The State of Rajasthan and Anr. (Respondent)
CRIMINAL APPEAL NO(S). OF 2026 (Arising out of SLP (Crl.) No (s). 1977 of 2026)
(3JB, Vikran Nath, Sandeep Mehta, N.V. Anjaria, JJJ.)
Overview
The case came before the Supreme Court where it examined that whether a murder conviction which is based solely on circumstantial evidence, sustainable. The appellant, Pooranmal, had been convicted with another person, Ladu Lal for the murder of Mr. Lal’s wife. The trial court sentenced both of them to life imprisonment. Later on, this conviction was also upheld by the Rajasthan High Court.
Following this, Pooranmal approached the Apex Court through legal aid after a long delay, explaining that he was unable to file an appeal earlier due to some financial issues.
Since there were no eye witnesses in the matter, the prosecution relied only on circumstantial evidence. The major circumstances were the alleged recovery of money from the appellant, call records, showing frequent contact between both the accused, and recovery of a blood stain-shirt.
The Supreme Court had to decide whether these circumstances led to the appellant being guilty of the accusations.
Facts
The case began on 2-3 March 2010 at the house of Ladu Lal, the other accused in Bhilwara, Rajasthan. As stated by Ladu Lal, around 1:30 a.m., he woke up and found out that his room has been bolted from outside. When he tried calling his wife on her phone, who was sleeping in another room, she didn’t respond. He then contacted his brother and a known police official. After a while, people gathered and the door was open from the outside. When they entered the room, Ladu Lal‘s wife was found lying on the bed with injuries and certain signs of struggle. She had died already. It was observed that the cupboard in the room was open and a large sum of amount was missing.
Initially, a case was registered against some unknown people. But later on, as the investigation progressed, the police started suspecting Ladu Lal himself. After the interrogation, he confessed that he planned the murder with the appellant herein, Pooranmal. Based on the same, the appellant was arrested.
The police officials claimed that they recovered Rs. 46,000, a blood-stained shirt from the possession of Pooranmal, and even collected some call details showing frequent communication between both of them around the time of the incident. Relying on these circumstances, the trial court convicted both of them for murder, and the Rajasthan High Court later upheld the conviction.
Legal Issues
- Whether the prosecution was successful in establishing a proper chain of circumstantial evidence, which linked the appellant to the murder.
- Whether the recovery of Rs. 46,000 and blood-stained shirt from the appellant could be treated as a reliable evidence.
- Whether the call records were admissible without any certification, which is required under Section 65B of the Evidence Act.
Decision
The Apex Court observed that the evidence relied upon is weak in nature. Firstly, the recovery of the money from the appellant, was doubtful because there was certain discrepancy in the amount and the prosecution also failed to establish any clear connection between the money and the crime. Secondly, although the forensic report stated that the blood on the blood-stained shirt matched the blood group of the deceased, it was found out that the prosecution failed to prove a proper chain of the custody of the articles which were seized. There were some issues in the evidence as to the samples which were sent to the forensic lab. Due to this, the reliability of the forensic report was doubtful. Thirdly, it was held that the call records could not be relied upon because the prosecution failed to produce the mandatory certificate required for electronic evidence under Section 65B of the Evidence Act.
Since these circumstances could not form a complete and reliable chain of events which could confirm the guilt of the appellant, the Supreme Court held that the conviction was unsustainable, which led to acquittal of Pooranmal.
