Facts: The appellant, Pooranmal, was convicted for the murder of Aruna (the wife of co-convict Ladu Lal) and for causing the disappearance of evidence. The prosecution's case rested on circumstantial evidence, primarily three links: frequent telephonic contact between the appellant and Ladu Lal around the time of the incident, the recovery of a blood-stained shirt from the appellant’s house matching the deceased's blood group (Group O), and the recovery of Rs. 46,000/- allegedly paid as blood money. The trial court and the High Court concurrently convicted the appellant, sentencing him to life imprisonment. While Ladu Lal’s appeal was previously dismissed, the Supreme Court entertained Pooranmal’s legal aid appeal due to distinguishing features in the evidence against him.
Procedural Posture: The appellant approached the Supreme Court via a Special Leave Petition (Criminal), challenging the judgment of the Rajasthan High Court which had affirmed the trial court's conviction under Sections 302/34 and 201 of the Indian Penal Code.
Issue: Whether the circumstantial evidence, comprising recovery of articles and electronic records, was sufficient to establish an unbroken chain of guilt in the absence of a mandatory certificate under Section 65-B of the Evidence Act and amidst discrepancies in the chain of custody?
Holding: No, the conviction cannot be sustained. The Supreme Court acquitted the appellant, holding that the prosecution failed to establish a complete and coherent chain of incriminating circumstances.
Reasoning: The Court applied the principles of "Sharad Birdhichand Sarda", emphasizing that circumstances "must" be fully established. First, the recovery of currency notes was doubtful due to a numerical discrepancy (Rs. 46,145/- found vs. Rs. 46,000/- recorded) and lacked a nexus to the crime. Second, the recovery of the blood-stained shirt was deemed unnatural as the appellant, being "at large" for days, would likely have destroyed it rather than concealing it. More importantly, the "link evidence" for the shirt was broken because the malkhana register and witness testimonies showed a breach in the chain of custody, making the FSL report unreliable. Finally, the Call Detail Records were ruled inadmissible because the mandatory certificate under Section 65-B(4) of the Evidence Act was not produced, following the precedents of "Anvar P.V." and "Arjun Panditrao".