Pooranmal was convicted by the Additional Sessions Judge, Bhilwara, along with co-accused Ladu Lal for the murder of Ladu Lal's wife, Smt. Aruna, under Sections 302/34 and 201 IPC, and sentenced to life imprisonment. The High Court of Rajasthan at Jodhpur affirmed the conviction. Ladu Lal's SLP was dismissed in limine by the Supreme Court. Pooranmal, unable to appeal earlier owing to poverty and lack of legal access, filed the present Criminal Appeal (No. 1266 of 2026) through legal aid — a delay of 2,749 days, which was condoned. The prosecution's case against Pooranmal rested entirely on three circumstantial strands: call detail records showing frequent contact with Ladu Lal around the time of the incident; recovery of a blood-stained shirt (FSL-confirmed blood group O, matching the deceased); and recovery of Rs. 46,000/- in currency notes allegedly paid as consideration for the murder.
Allowed. The Supreme Court set aside the conviction on all three limbs. First, the currency note recovery was held doubtful — the amount sealed as Rs. 46,000/- was counted in court as Rs. 46,145/-, and in any event mere possession of currency notes, without cogent evidence of a nexus to the crime, cannot constitute an incriminating circumstance. Second, the blood-stained shirt recovery was found unreliable: it was improbable that a free man would meticulously conceal rather than destroy or wash the shirt; and critically, the chain of custody was broken — the malkhana register (Ex. D-3) showed the muddamal articles were sent out on 12th March 2010, yet PW.19 and PW.16 gave contradictory accounts, with PW.16 denying any movement before 18th March 2010. Relying on Karandeep Sharma alias Razia alias Raju v. State of Uttarakhand [2025 SCC OnLine SC 773] and Allarakha Habib Memon v. State of Gujarat [(2024) 9 SCC 546], the Court held that a broken chain of custody renders the FSL report worthless, and that a matching blood group on a recovered article is not, by itself, sufficient to link the accused to the crime. Third, the call detail records were inadmissible: the mandatory certificate under Section 65-B of the Evidence Act [Section 63 of the BSA] was never proved, and oral evidence of the nodal officers (PW.23 and PW.24) cannot substitute for it — reaffirming Anvar P.V. v. P.K. Basheer [(2014) 10 SCC 473] and Arjun Panditrao Khotkar v. Kailash Kushanrao Gorantyal [(2020) 7 SCC 1].
The Court distinguished Pooranmal's case from that of co-convict Ladu Lal, whose conviction additionally rested on the reverse burden under Section 106 of the Evidence Act — a basis entirely absent against Pooranmal. Applying the five-point test in Sharad Birdhichand Sarda v. State of Maharashtra [(1984) 4 SCC 116], the Court found the prosecution had failed to establish a complete and unbroken chain of incriminating circumstances. Pooranmal was acquitted and directed to be released forthwith.