Evidentiary Value of Forensic Science Lab Report: SC Acquits Man in Key Case

In a significant judgment this November 2025, the Supreme Court of India acquitted a man convicted of murder, delivering a sharp reiteration of foundational criminal law principles. The Court ruled that the mere recovery of an alleged murder weapon, even when supported by a matching Forensic Science Lab (FSL) report, is insufficient to sustain a conviction in the absence of a complete and credible chain of corroborating evidence.

The ruling came in a case where the prosecution’s entire narrative collapsed after its key eyewitnesses turned hostile. The apex court’s decision meticulously dismantles a conviction that was standing on only two pieces of evidence: a recovered pistol and a forensic report linking it to bullets found in the deceased.

The judgment underscores that forensic science is a tool to aid prosecution, not a substitute for it. It serves as a stark reminder to trial courts that a ballistic report, no matter how precise, cannot by itself prove that the accused, and no one else, pulled the trigger.

The Collapse of the Primary Evidence

The prosecution's case began with what appeared to be a solid foundation: two eyewitnesses who had allegedly seen the appellant commit the murder. However, during the trial, this foundation turned to dust.

Both key witnesses—one of whom was the complainant—turned hostile. They did not support the prosecution's case in court and specifically did not identify the appellant as the assailant. This left the prosecution with a case built not on direct human testimony, but entirely on circumstantial evidence.

For a case resting on circumstantial evidence, the law demands an exceptionally high standard of proof. The prosecution must establish a complete, unbroken chain of events that points only to the guilt of the accused, excluding all other possible hypotheses.

It was in this context that the Supreme Court examined the two-remaining links in the prosecution's broken chain: the recovery of the alleged weapon and the FSL report.

A 'Discovery' from an Unsecured Location

The prosecution's second pillar was the recovery of a country-made pistol and live cartridges, allegedly based on a disclosure statement made by the appellant while in police custody. Such recoveries are governed by Section 27 of the Indian Evidence Act, 1872.

However, the Supreme Court found the nature of this recovery to be deeply problematic. The pistol was not found hidden in a place of special, exclusive knowledge to the appellant. Instead, it was recovered from an unlocked box in a house where other family members also resided.

The Court observed that a recovery from a place accessible to others holds minimal evidentiary value. To be a strong piece of evidence, the discovery must be from a location that only the accused could have known about, thereby "distinctly" connecting him to the hidden object. An unlocked box in a family home failed this test.

This finding strikes at the heart of many routine recoveries. It serves as a judicial warning against attributing a weapon to an accused simply because it was found in their general vicinity, especially when that vicinity is shared with others.

The 'Distinct' Requirement of Section 27

Delving deeper into the legal technicality, the Supreme Court scrutinized the disclosure statement itself. For a statement under Section 27 to be admissible, it must "distinctly" relate to the fact discovered.

The Court noted that the appellant’s disclosure statement merely said he could get a pistol recovered; it did not state that this was the specific pistol used in the commission of the murder. This is a subtle but critical distinction.

The bench held that the word "distinctly" must be given its full weight. The prosecution failed to establish that the information provided by the accused was of a nature that distinctly and unmistakably connected the recovered object to the crime itself. Without this direct link, the recovery was reduced to the mere discovery of an unlicensed firearm, not the discovery of the actual murder weapon.

Forensic Report: Corroboration, Not Primary Proof

The final and most critical piece of evidence was the FSL report, which confirmed that the bullets found in the deceased's body were fired from the same pistol recovered from the unlocked box. The High Court had leaned heavily on this "scientific evidence" to uphold the conviction, reasoning that it was a modern, infallible proof.

The Supreme Court rejected this line of reasoning in no uncertain terms.

It held that an FSL report can only corroborate other, more foundational evidence. By itself, it is insufficient to establish guilt. The report proved that the pistol was the murder weapon. It did not—and could not—prove that the appellant was the one who used it.

With the eyewitnesses having turned hostile, there was no primary evidence left for the FSL report to corroborate. The Court made it clear:

• Hostile Witnesses: The testimony linking the appellant to the crime was gone.

• Weak Recovery: The evidence linking the appellant to the weapon was dubious, given its unsecured location.

Therefore, the only remaining link was between the weapon and the victim. The link between the appellant and the weapon, or the appellant and the crime, was missing. The Court ruled that forensic evidence cannot be used to bridge this fundamental gap in the prosecution's narrative.

Furthermore, the Court identified another glaring lapse: a 19-day gap between the seizure of the weapon and its deposit at the FSL. This unexplained delay, the Court noted, fatally broke the chain of custody, leaving the evidence open to tampering and contamination.

This judgment reaffirms a cardinal rule of criminal justice: technology cannot convict a person. The prosecution's duty to prove its case "beyond a reasonable doubt" remains a human and procedural one, requiring a complete chain of credible evidence from the crime scene to the courtroom.