Forensic Doubt and Presumption of Innocence: A Critical Analysis of State of Rajasthan v. Hanuman (2025)

Index

1. Synopsis
2. Introduction
3. Factual Background and Trial Court Conviction
4. High Court’s Appellate Reversal and Reasoning
5. Supreme Court's Analysis: Circumstantial Standards and Forensic Weakness
6. Judicial Precedent: Raja Naykar and the Limits of Blood Group Evidence
7. 7.Motive and Its Evidentiary Frailty
8. 8.Appeals Against Acquittal: The Standard of Cautious Non-Interference
9. 9.Section 27 of the Indian Evidence Act and the Doctrine of Recovery
10. 10.The Role and Limits of Forensic Evidence: A Constitutional Perspective
11. 11.Constitutional Safeguards and Presumption of Innocence
12. 12.Conclusion: A Verdict Anchored in Juridical Discipline
13. 13.FAQs

Synopsis

This article examines the Supreme Court’s 2025 ruling in State of Rajasthan v. Hanuman, which upheld the acquittal of a murder accused due to insufficient circumstantial evidence. The prosecution relied on a vague motive, recovery of a blood-stained weapon, and an FSL report matching the blood group of the deceased. However, the Court found that these elements, taken individually or collectively, did not form a conclusive and unbroken chain pointing only to the accused’s guilt.

The article explores the Court's reliance on precedents such as Raja Naykar, Sharad Birdhichand, and Kali Ram, all of which underscore that suspicion or partial forensic evidence cannot replace proof beyond reasonable doubt. It further discusses the evidentiary value of motive, the limitations of forensic science when not corroborated, the cautious approach required in overturning acquittals, and the constitutional doctrine of presumption of innocence under Article 21.

In doing so, this article reaffirms the Supreme Court’s fidelity to fair trial standards, evidentiary rigor, and constitutional protections in criminal jurisprudence. It argues that the Hanuman ruling is not merely a fact-specific outcome but a precedent-guided affirmation of liberty and procedural integrity in Indian criminal law.

Introduction

The Indian criminal law jurisprudence places firmly on the prosecution the onus of establishing the guilt of the accused beyond all reasonable doubt. Such a test is still more rigorous in cases based purely on circumstantial evidence and where every link in the chain of evidence must be unbroken, complete, and free from every hypothesis except the guilt. 

The recent ruling of Hon'ble Supreme Court in State of Rajasthan v. Hanuman, Criminal Appeal No. 631 of 2017 (dated 19 June 2025) is a strong reiteration of such principles. In rejecting the appeal of the State and confirming the respondent's acquittal, the Court emphasized the constitutional right of the presumption of innocence and examined the shortcomings of forensic and circumstantial evidence that were non-conclusive in nature.

Factual Background and Conviction by Trial Court

The prosecution was based on a murder that took place on the intervening night of 1st and 2nd March 2007. Chotu Lal, the victim, was murdered, and FIR was at first registered against some unknown persons. With time, suspicion fell on the respondent, Hanuman. He was held guilty by the trial court under Section 302 of the Indian Penal Code. The pivotal facts on which reliance was placed were: (i) stated motive due to the respondent's alleged ill will towards the wife of the deceased; (ii) the discovery of a blood-stained weapon at the instance of the respondent; and (iii) an FSL report stating that the blood on the weapon was of the same blood group as the deceased (B+ve) (see SC judgment, paras 2–3).

The Additional Sessions Judge No. 1, Fast Track, Kota, believed the prosecution version and convicted the respondent to a life imprisonment sentence along with a token fine. Yet, no eyewitnesses had been produced, and the whole case had depended on these indirect connections.
High Court's Appellate Reversal and Reasoning
In appeal, the Rajasthan High Court reversed the conviction by judgment dated 15 May 2015. The Division Bench held that the prosecution was unable to create a conclusive chain of events. The motive, which was the psychological anchor of the case, was held to be vague and uncorroborated. Additionally, the recovery of the weapon and the supporting FSL report, even if believed, did not rule out the existence of alternative explanations.
In its rationale (mentioned in SC para 4), the High Court pointed out that the line of circumstantial evidence was ruptured at several points. It held that no link between the accused and the lethal act had been established, and hence, applied the benefit of doubt in the respondent's favour.

Supreme Court's Analysis

In the 19 June 2025 decision, the Supreme Court did a reassessment of the record. At paragraph 6, the Court admitted that even if the High Court could have overlooked the FSL report, its addition would not have made any difference. The weapon had blood belonging to the group of the deceased, but the prosecution could not establish how the blood got there or definitely prove that the weapon was used in the killing.

The Court concluded that even cumulatively, the motive and recovery did not constitute a complete chain of guilt. This analysis echoes the five-point test established in Sharad Birdhichand Sarda v. State of Maharashtra. There, in paragraph 153, the Constitution Bench had required that the chain of events must be complete, point unequivocally to guilt, and rule out any reasonable hypothesis of innocence. In Hanuman, these conditions were prominently unfulfilled.

Judicial Precedent

The Supreme Court rested its reasoning on the precedent of Raja Naykar v. State of Chhattisgarh, referred to specifically in paragraph 7 of the Hanuman judgment. In Raja Naykar, the Court stated that the mere recovery of a blood-stained weapon with the same blood group as the victim was not enough to support a conviction unless the prosecution could prove, with direct or circumstantial certainty, that the weapon had indeed been used for the purposes of the offence (para 14, Raja Naykar).

The Court reaffirmed this test in Hanuman, noting that such forensic evidence, though maybe suggestive, does not amount to conclusive proof. The matching of blood groups alone, without more contextual connecting factors, falls below the test of proof beyond reasonable doubt.

Motive and Its Evidentiary Frailty

A vital failure in the case for the prosecution was the lack of motive. As explained in paragraph 8 of the judgment, the claim that the accused had an evil eye for the wife of the deceased was uncorroborated. The prosecution failed to provide any witnesses or evidence admissible in court to support the claim. Motive, assuming it is believed, can only give background and cannot be the sole basis for conviction.

This approach of the Court has been in line with established jurisprudence, such as in Subramaniam v. State of Tamil Nadu, where the Supreme Court held that in circumstances cases, motive is a minor role player and can only be established by cogent evidence of corresponding conduct or history (para 22, Subramaniam). In Hanuman, no such supportive material was present, making the motive at best speculative.

Appeals From Acquittal: The Doctrine of Cautious Non-Interference

One notable aspect of the Supreme Court's decision in State of Rajasthan v. Hanuman is its careful observance of the judicial restraint in appeals from acquittal. Paragraph 9 of the judgment encapsulates this doctrine by affirming once again that interference with an acquittal would be resorted to only if the perception of the error made by the lower court was so glaringly puerile that it led to a miscarriage of justice. 

The Court noted that except where the High Court's judgment was manifestly incorrect or not based on the evidence on record, intervention by the appellate court was not warranted. In this case, the findings of the High Court were based not only on the prosecution's case evidence limitations but were, in the Supreme Court's view, "the only possible view" on the record and facts.

This measured approach is not new. It is deeply ingrained in the Supreme Court's jurisprudence. The rule was early enunciated in Chandrappa v. State of Karnataka,, wherein the Court at paragraph 42 held that when the trial court has acquitted an accused, the appellate court should not lightly uproot such conclusions.

Although the jurisdiction of an appellate court under Section 378 of the CrPC is complete, the criteria for reversing acquittals are higher than for the confirmation of convictions. The rationale lies in the dual presumption—first, the accused is presumed innocent until proven guilty; and second, upon acquittal, this presumption is further reinforced.

The Court has exercised identical restraint in Vijay Kumar Arora v. State (NCT of Delhi),, wherein it held that "appellate interference is warranted only if the view adopted by the trial court is perverse or irrational, and not because another possible view is available." The rationale here derives from the jurisprudential theory that criminal law per se is concerned with safeguarding personal liberty, and that wrongful conviction poses a much greater risk than wrongful acquittal. In Hanuman, the High Court's acquittal was not plagued by any irrationality but was instead grounded in a realistic and constitutionally valid evaluation of threadbare circumstantial evidence.

Thus, the Supreme Court's validation of the acquittal is more than a procedural validation of the opinion of a lower court but also a principled position on the constitutional principles of fairness, liberty, and evidence integrity.

Section 27 of IndianEvidence Act and the Doctrine of Recovery

The recovery of a weapon supposedly fabricated on the prompting of the accused under Section 27 of the Indian Evidence Act was another significant evidentiary factor examined in Hanuman. This section contains an exception to the general rule that police officers' confessions are not admissible. If a fact is uncovered through information provided by an accused in custody, such information leading to the discovery is admissible. Yet, the effectiveness of Section 27 depends on the credibility and conclusiveness of the recovered item's connection to the offence.

In Hanuman, although a weapon with blood on it was seized, the prosecution was unable to create a clear link between the weapon and the actual fact of homicide. There was no forensic report to prove that the blood stains were recently deposited, nor was there any DNA test conducted to specifically connect the blood on the weapon to the victim. The FSL only stated a match of blood group (B+ve), which is fairly prevalent and hence inconclusive. Even being admissible under Section 27, the value of the evidence of recovery was greatly undermined.

This point of law finds root exposition in Pulukuri Kottaya v. Emperor, wherein the Privy Council warned that the information under Section 27 admissible should directly result in the discovery of a fact not known to the police, and that the object found should be meaningfully related to the crime. 

more recent jurisprudence, e.g., Aftab Ahmad Ansari v. State of West Bengal, the Supreme Court reiterated that recovery per se does not prove guilt unless the object is established to be employed in the commission of the offence and the circumstances surrounding it rule out any alternative inference.

In Hanuman, this requirement was not satisfied. No witness was produced by the prosecution to establish that the accused alone knew where the weapon was. There was no chain of custody or circumstantial connection between the commission of the murder and the recovery as well. Accordingly, even a Section 27 compliant recovery failed to become evidence legally relevant and incriminating in nature.

The Role and Limitations of Forensic Evidence: A Constitutional Analysis

With the era of digital and forensic developments, scientific evidence has gained a more leading role in criminal prosecutions. Yet Hanuman proves that forensic evidence, although significant, is incapable of replacing the very essence of a logical and compelling evidentiary story. Reasoning in this vein is evident in Paragraph 6 of the judgment of the Supreme Court. The Court expressed the view that although if the FSL report—indicating blood group match—were considered, it was not enough to seal the evidentiary chain.

This distinction is critical. It is not necessary that forensic evidence can always be trusted. It must be investigated, corroborated and judicially interpreted with caution. In Krishna Ghosh v. State of Jharkhand, the Supreme Court warned against blind reliance on scientific results without explaining their relevance in context. The Court held that “evidence from the laboratory must be supported by surrounding facts and must be proven to be free from tampering or doubt.”

In Hanuman, no explanation was provided as to how the blood got onto the weapon or whether it was deposited at all during the commission of the offence. The presence of B+ve blood—something which is found in a high percentage of the population—on a weapon that is found days or even weeks later does not possess such probative value as is necessary for a conviction for murder. The lack of any DNA testing or fingerprint proof further diluted the argument that the weapon belonged to, and was in possession of, the accused.

This strategy is well embedded in the constitutional concept of due process. Article 21 of the Constitution assures life and personal liberty and mandates that no individual shall be deprived of it except according to procedure established by law. That "procedure" has been construed by the Supreme Court in a series of cases—in Maneka Gandhi v. Union of India, for example—since as just, fair, and reasonable. Convicting someone on doubtful forensic grounds, lacking definite associations and corroboration, would be contrary to this constitutional protection.

Presumption of Innocence and Constitutional Safeguards

The final and necessary building block for the Hanuman verdict is the Court's observance of the presumption of innocence. This presumption is implicit in the right to fair trial under Article 21, has been recognized as a human rights principle under international instruments like Article 14(2) of the ICCPR, to which India is a signatory.

In Kali Ram v. State of Himachal Pradesh, the Supreme Court reiterates that the principle of presumption of innocence is an integral part of criminal jurisprudence and must be strengthened where the evidence is meager or uncertain. The Court well stated at paragraph 25 that "a miscarriage of justice which may arise from the acquittal of the guilty is less than that which from the conviction of the innocent."

In Hanuman, the lack of direct evidence, absence of eyewitnesses, uncertainty regarding the motive, and forensic inconclusiveness placed the accused in a position where he could not be presumed to be guilty beyond reasonable doubt. The Supreme Court was correct in pointing out that the advantage of such doubt should accrue to the accused and that the freedom of an individual should not be offered as a sacrifice on the altars of prosecutorial failure.

Conclusion

The Supreme Court’s ruling in State of Rajasthan v. Hanuman stands as a constitutional reaffirmation of the evidentiary and procedural rigor demanded in criminal trials. It reinforces the axiom that suspicion, however strong, cannot be a substitute for legal proof. By refusing to convict the respondent based on a shaky combination of motive, weak forensic inference, and inconclusive recovery, the Court has underlined that criminal law’s ultimate goal is not conviction but justice.

The judgment revisits and reasserts vital legal doctrines: the need for an unbroken chain of circumstances in circumstantial evidence cases, the limitations of blood group forensics in the absence of DNA proof, the constraints on appellate interference in acquittals, and the continuing vitality of the presumption of innocence. In an era where forensic evidence often carries overwhelming weight in public discourse, Hanuman serves as a judicial counterbalance, insisting that every piece of evidence must be not only admissible but probatively potent and legally relevant.

By rooting its reasoning in the spirit of Sharad Birdhichand, Raja Naykar, Chandrappa, Pulukuri Kottaya, and Kali Ram, the Supreme Court has ensured that the evolution of Indian criminal law remains in consonance with constitutional morality and procedural due process. Hanuman is thus not just a routine acquittal judgment—it is a principled reaffirmation of the safeguards that insulate the innocent from wrongful conviction.

FAQs

Q1. What was the main issue in State of Rajasthan v. Hanuman?
Whether the circumstantial evidence presented—motive, blood group match, and weapon recovery—was sufficient to convict the accused for murder.

Q2. Why did the Supreme Court uphold the acquittal?
The Court found that the chain of evidence was incomplete and inconclusive. Neither the motive nor the forensic report conclusively linked the accused to the crime.

Q3. What precedent guided the Court’s view on blood-stained weapon recovery?
Raja Naykar v. State of Chhattisgarh (2024) 3 SCC 481, which held that matching blood groups alone do not prove guilt without a direct link to the crime.

Q4. How did the Court treat the alleged motive?
It found the motive—an alleged evil eye on the deceased’s wife—too vague and unsupported to serve as a reliable circumstance.

Q5. What is the principle under Section 27 of the Evidence Act and was it useful here?
Section 27 allows admissibility of information leading to discovery during custody. However, in Hanuman, the recovered weapon lacked conclusive links to the crime.

Q6. Can the Supreme Court easily reverse acquittals?
No. As per Chandrappa v. State of Karnataka, reversal of acquittal is warranted only when the High Court’s view is perverse or wholly unreasonable.

Q7. What constitutional right was reinforced by this ruling?
The presumption of innocence under Article 21, which protects individuals from being convicted without clear and convincing evidence.

Q8. What does this judgment signify for future circumstantial evidence cases?
It reiterates that courts must insist on complete and coherent chains of evidence and must not convict merely on suspicion or partial proof.