The Supreme Court has acquitted a man convicted of murder after finding that the prosecution failed to establish a complete chain of circumstantial evidence, holding that doubtful recoveries, a broken chain of custody of forensic samples, and inadmissible call detail records could not sustain a murder conviction.
- Case: Pooranmal v. State of Rajasthan & Anr.
- Court: Supreme Court of India
- Bench: Justice Vikram Nath, Justice Sandeep Mehta, Justice N.V. Anjaria
- Date of Judgment: March 10, 2026
- Citation: 2026 INSC 217
- Case Type: Criminal Appeal (Arising out of SLP (Crl.) No. 1977 of 2026)
Supreme Court Acquits Pooranmal in Aruna Murder Case
Case Background
The case arose from the alleged murder of Smt. Aruna, wife of Ladu Lal, was murdered during the night between March 2 and March 3, 2010, at the couple’s residence in Bhilwara, Rajasthan.
According to the prosecution, Pooranmal, along with Ladu Lal, conspired to kill Aruna in her home.
The incident came to light when Ladu Lal himself lodged a report with the police. He claimed that he had been sleeping in the drawing room with his son while his wife slept in another room.
Around 1:30 a.m., he allegedly woke up to attend nature’s call but discovered that his room had been bolted from outside. When he attempted to contact his wife by phone and received no response, he contacted relatives and acquaintances.
After the door was opened, Aruna was found lying on the bed with visible injuries on her head and signs of struggle. She had died by the time people entered the room.
An almirah in the room was found open, and approximately ₹4 lakh was reported missing. Ladu Lal initially alleged that unknown persons had committed the murder and robbery. Based on his report, an FIR was registered under Section 460 of the Indian Penal Code (now Section 331(8) of the Bharatiya Nyaya Sanhita).
During the investigation, suspicion turned toward Ladu Lal due to inconsistencies in his statements. After his arrest, he allegedly made a disclosure statement implicating Pooranmal.
Subsequently, the police arrested Pooranmal and claimed to have recovered a blood-stained shirt and ₹46,000 from him. Investigators also obtained call detail records showing communication between the two accused around the time of the incident.
Trial and High Court Conviction
Following the investigation, a chargesheet was filed against both accused for offences under Sections 302/34 and 201 of the IPC (corresponding to Sections 103(1)/3(5) and 238 of the Bharatiya Nyaya Sanhita).
The trial court convicted both men in February 2012.
They were sentenced to life imprisonment for murder and seven years’ rigorous imprisonment for causing the disappearance of evidence. The sentences were ordered to run concurrently.
The Rajasthan High Court upheld the conviction in March 2018. Ladu Lal later approached the Supreme Court through a Special Leave Petition, which was dismissed in 2022.
Pooranmal, however, could not file an appeal earlier due to poverty and lack of legal assistance. His appeal was eventually filed through legal aid, and the Supreme Court condoned a delay of 2,749 days while deciding to examine the merits of the case.
Prosecution Case Based Entirely on Circumstantial Evidence
The Supreme Court observed that the prosecution’s case against Pooranmal rested solely on circumstantial evidence. Specifically, three circumstances were relied upon:
- Call detail records indicate frequent communication between Pooranmal and Ladu Lal around the time of the incident.
- Recovery of a blood-stained shirt allegedly worn during the crime.
- Recovery of ₹46,000 said to have been paid to Pooranmal for committing the murder.
The Court reiterated the established legal principles governing cases based on circumstantial evidence, referring to the landmark decision in Sharad Birdhichand Sarda v. State of Maharashtra. The judgment emphasized that each circumstance must be conclusively proved and must form a complete chain pointing only to the guilt of the accused.
Doubtful Recovery of Currency Notes
The Court first examined the alleged recovery of ₹46,000 from the appellant.
A key discrepancy emerged during the evidence of the investigating officer. While the seizure memo recorded recovery of ₹46,000, the amount counted in court turned out to be ₹46,145. The officer admitted that the additional ₹145 was not mentioned on the sealed packet.
The Court held that this discrepancy cast serious doubt on the very fact of recovery. Moreover, even if the money had been recovered, there was no credible evidence linking the amount to the alleged payment for committing the murder.
The Court observed that mere possession of currency notes, without evidence establishing a clear connection to the crime, could not be treated as an incriminating circumstance.
Blood-Stained Shirt Recovery Found Unreliable
The second circumstance relied upon was the recovery of a shirt allegedly stained with blood matching the deceased’s blood group.
The Court found the circumstances surrounding this recovery improbable. According to the prosecution, Pooranmal had concealed the shirt inside an iron box despite having been free for two days after the incident.
The bench remarked that it was “highly improbable and unnatural” for a person who had committed a murder to preserve a blood-stained shirt rather than destroy it or wash away the stains.
More importantly, the Court found serious deficiencies in the chain of custody of the seized articles.
Evidence from police witnesses revealed contradictions regarding when the samples were sent to the forensic laboratory. Entries in the malkhana register indicated that the samples were forwarded earlier than claimed, and there was no clear explanation for why they had been returned from the forensic laboratory before being sent again.
The Court held that such discrepancies broke the mandatory chain of custody required to establish the authenticity of forensic evidence.
Referring to earlier precedent, the Court emphasized that forensic evidence is reliable only when the prosecution proves that the samples remained sealed and untampered from the time of seizure until their examination at the laboratory.
Because the prosecution failed to establish this chain, the Court concluded that the forensic report lost evidentiary value.
The judgment stated that the FSL report effectively became “a worthless piece of paper” due to the breach in the chain of custody.
Call Detail Records Held Inadmissible
The final piece of evidence relied upon by the prosecution was the call detail records indicating communication between the two accused.
The Supreme Court held that these records were inadmissible because the prosecution had failed to produce the mandatory certificate required under Section 65B of the Evidence Act.
The Court reiterated the legal position laid down in Anvar P.V. v. P.K. Basheer and reaffirmed in Arjun Panditrao Khotkar v. Kailash Kushanrao Gorantyal, which makes such certification a mandatory requirement for the admissibility of electronic evidence.
The judgment emphasized that oral testimony by telecom company officials cannot substitute the statutory certificate.
Without compliance with Section 65B, the call detail records could not be relied upon in evidence.
Failure to Establish Complete Chain of Circumstances
After analyzing the evidence, the Court concluded that none of the alleged circumstances could be treated as reliable.
The recovery of money was doubtful, the recovery of the shirt was unreliable, the forensic evidence was rendered meaningless due to a broken chain of custody, and the call detail records were inadmissible.
Consequently, the prosecution failed to establish a complete chain of circumstances pointing to the guilt of the accused.
The Court observed that the evidence did not form “an unbroken chain pointing unequivocally towards the guilt” of Pooranmal.
Supreme Court Sets Aside Conviction
Allowing the appeal, the Supreme Court set aside the judgments of both the trial court and the Rajasthan High Court.
The Court held that the prosecution had “miserably failed” to prove the charges against the appellant.
Pooranmal was acquitted of all charges and ordered to be released immediately if not required in any other case.
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