Conviction Cannot Rest on Circumstantial Evidence Without Complete Chain and Admissible Electronic Proof: Supreme Court Acquits Accused

Case Name: Pooranmal v. State of Rajasthan & Anr.

Citation: 2026 INSC 217; Criminal Appeal arising out of SLP (Crl.) No. 1977 of 2026

Date of Judgment/Order: 10 March 2026

Bench: Hon’ble Mr. Justice Vikram Nath, Hon’ble Mr. Justice Sandeep Mehta and Hon’ble Mr. Justice N. V. Anjaria

Held: The Supreme Court held that a conviction based solely on circumstantial evidence cannot be sustained unless the prosecution establishes a complete and unbroken chain of circumstances pointing conclusively to the guilt of the accused. The Court further held that electronic evidence such as call detail records is inadmissible in the absence of the mandatory certificate under Section 65B of the Indian Evidence Act. The Court also emphasised that forensic reports cannot be relied upon unless the prosecution establishes the integrity and continuity of the chain of custody of seized articles. In the absence of reliable recoveries, admissible electronic evidence, and a coherent chain of circumstances, conviction cannot be maintained.

Summary: The case arose from the alleged murder of a woman in Rajasthan in March 2010. The prosecution alleged that the appellant, along with a co-accused who was the husband of the deceased, murdered the victim and attempted to conceal the crime. Initially, the husband reported the incident claiming that unknown persons had murdered his wife and stolen money from the house. During investigation, suspicion turned toward the husband, who allegedly made a disclosure implicating the appellant. The prosecution case against the appellant was entirely based on circumstantial evidence, primarily three circumstances: frequent telephonic contact between the appellant and the co-accused around the time of the incident, recovery of a blood-stained shirt allegedly belonging to the appellant, and recovery of INR 46,000 which the prosecution claimed was payment for committing the murder. The trial court convicted both accused persons under Sections 302/34 and 201 IPC and sentenced them to life imprisonment. The High Court affirmed the conviction. Before the Supreme Court, the appellant challenged the reliability of the alleged recoveries and the admissibility of the electronic evidence. The Court examined the evidence and found serious discrepancies regarding the recovery of currency notes and held that mere possession of money without proof of its connection to the crime could not be treated as an incriminating circumstance. The Court further held that the recovery of the alleged blood-stained shirt was unreliable and the prosecution failed to establish an unbroken chain of custody for the seized articles, thereby undermining the credibility of the forensic report. With regard to the call detail records relied upon by the prosecution, the Court held that the mandatory certificate under Section 65B of the Evidence Act had not been produced and therefore the electronic evidence was inadmissible. In the absence of these pieces of evidence, the Court concluded that the prosecution had failed to establish the complete chain of circumstances required for conviction in cases based on circumstantial evidence.

Decision: The Supreme Court allowed the appeal, set aside the judgments of the trial court and the High Court convicting the appellant under Sections 302/34 and 201 IPC, acquitted the appellant of all charges, and directed that he be released forthwith if not required in any other case.