The Supreme Court has upheld the acquittal of a woman accused of murdering her stepmother and minor stepbrother, holding that a DNA match between her blood sample and blood found at the scene did not conclusively establish that she committed the murders.

The bench of Justice Manoj Misra and Justice Vijay Bishnoi dismissed the Himachal Pradesh government’s appeal after finding significant gaps in the prosecution’s circumstantial evidence. These included unreliable testimony concerning the accused’s presence with the deceased, doubtful recoveries, an uncertain time of death and failure to produce crucial mobile phone records.

Buy Now: Supreme Court Judgments E-Magazine – 5 Month Combo (2026) (1st February – 30th June 2026)

Background: Mother And Minor Son Found Dead

The case arose after Bhagi Ram informed the police on September 7, 2011, that his daughter, Mithilesh Kumari, had been missing for six to seven days, her house was locked and a foul smell was coming from inside.

The police entered the house at Diur and discovered the bodies of Mithilesh Kumari and her minor son, Bhupinder Singh. Medical evidence established that both had died from asphyxia caused by antemortem strangulation.

The prosecution alleged that Anchla alias Chanchla, a daughter of Mithilesh Kumari’s husband from his first marriage, had committed the murders to obtain property allegedly bequeathed by her father to Bhupinder Singh.

According to the prosecution, the accused visited the deceased’s house on August 31, 2011, returned to Chamba late that night with a bleeding thumb injury and stayed at a hotel. It also relied on the alleged recovery of the deceased’s mobile phone and a bunch of keys at the accused’s instance, together with forensic evidence connecting her blood to bloodstains found inside the house.

Trial Court Conviction And High Court Acquittal

The Sessions Court at Chamba convicted and sentenced the accused under Section 302 of the Indian Penal Code on November 7, 2012.

The trial court considered the alleged last-seen evidence, taxi journey, thumb injury, recoveries and DNA match sufficient to establish a chain pointing exclusively to her guilt.

However, the Himachal Pradesh High Court set aside the conviction on July 28, 2014. It found that the prosecution had failed to prove the murder charge beyond reasonable doubt.

The State challenged that acquittal before the Supreme Court, arguing that the High Court had rejected important evidence on conjectures and that the conviction should be restored.

DNA Evidence Could Establish Earlier Presence, Not Presence During The Murders

A central issue was the forensic finding that the accused’s DNA profile matched the profile generated from blood collected from a trunk or cabinet inside the deceased’s room.

The Supreme Court raised questions about the forensic material, including why some blood samples were too degraded for DNA profiling while samples from the cabinet yielded usable DNA. It also noted that the scientific expert had not been called for cross-examination and that the defence had made little effort to establish tampering with the seals.

In those circumstances, the Court accepted the forensic report as it stood. Nevertheless, it held that the DNA match did not conclusively connect the accused to the murders.

“Presence of blood of the accused in the room at best indicates that at some point in time the accused was present there,” the Court observed.

The prosecution itself acknowledged that the accused had regularly visited the deceased’s house. Consequently, an earlier injury causing her blood to fall on the cabinet could not be ruled out.

The Court also noted that her blood was not found on the deceased persons’ clothes or on any cloth or material that might have been used to strangle them. The forensic finding therefore did not establish her presence at the relevant time or prove that she was the perpetrator.

Last-Seen Evidence Was Not Proved Beyond Reasonable Doubt

The deceased woman’s father was the sole witness to the alleged last-seen circumstance. In court, he stated that he had seen the accused talking to the minor boy at the house on August 31, 2011.

However, his earlier statement to the police under Section 161 of the Code of Criminal Procedure did not contain that assertion. The Supreme Court treated the later version as an improvement over his previous account.

The Court considered it unsafe to conclude, solely on his testimony, that the accused was with the deceased that evening.

It also questioned his explanation for waiting six to seven days before reporting the disappearance, despite running a shop nearby and having been provided a room in his daughter’s house. His belief that she might have gone to Mani Mahesh had not been adequately investigated.

Taken together with the other evidentiary gaps, these circumstances undermined the prosecution’s claim that the accused had been present at the house on the alleged date.

Investigators Must Explain How Key Witnesses Were Located

The prosecution examined a taxi driver who claimed to have taken the accused from Chamba to Diur and back, and a hotel worker who claimed to have seen her at the hotel that night.

The Supreme Court found both witnesses untrustworthy.

A significant concern was the investigating officer’s failure to explain what prompted him to record their statements or clearly identify when those statements were recorded. There was no disclosed investigative lead connecting the accused to that taxi journey or hotel stay.

The Court explained that the circumstances in which a witness comes to the attention of investigators can help determine whether the witness naturally possesses relevant information or has been introduced to build a prosecution narrative.

It recognised that police may legitimately follow clues obtained from other statements. However, an unexplained decision to examine a person, without an apparent reason to believe that the person possesses relevant information, may cast doubt on the resulting evidence.

In this case, the Court considered the lack of explanation sufficient to seriously undermine the taxi driver’s and hotel worker’s credibility.

The absence of hotel records corroborating the accused’s alleged stay further weakened the hotel worker’s testimony.

Missing Mobile Tower Data Was A Serious Investigational Lapse

The Supreme Court criticised the failure to obtain tower location information corresponding to the call detail records of the accused and the deceased.

Such information could have helped assess whether their phones were near each other at the relevant time and whether the deceased’s phone subsequently moved to the accused’s place of residence, from where it was allegedly recovered.

The Court also noted that the deceased’s call detail record, although collected during investigation, had not been exhibited in evidence. The investigating officer did not clarify whether her phone remained operational after August 31, 2011.

These records could have tested the witness’s claim that the deceased’s phone was switched off and helped examine the prosecution’s proposed timeline.

The Court found that withholding the deceased’s call records and tower location information created an impression that vital information was being suppressed.

Medical Evidence Did Not Fix The Alleged Murder Date

Although the medical evidence established homicidal deaths, it did not conclusively establish that the murders occurred during the intervening night of August 31 and September 1, 2011.

The autopsies were conducted on September 8, 2011. The doctor estimated that death had occurred five to seven days earlier.

The Supreme Court held that this evidence did not rule out the possibility of death occurring later, including on September 1 or September 2. That uncertainty weakened the attempt to link the alleged August 31 visit directly to the murders.

Recovery Of Keys Failed To Establish The Necessary Link

The prosecution relied on a forensic finding that keys allegedly recovered at the accused’s instance operated a lock produced in evidence.

However, the Supreme Court held that the prosecution first needed to establish that this was the same lock that had secured the deceased’s house and had been broken to gain entry.

The witness who identified the lock stated that he had seen it on the door handle rather than the latch. Another witness who spoke of the lock being broken did not identify the lock produced in court. The investigating officer arrived after the lock had already been broken.

The Court therefore found that the identity of the relevant lock had not been established beyond reasonable doubt. Without that foundational link, the recovery of the keys could not reliably connect the accused to the crime.

The alleged recovery of the deceased’s mobile phone also failed to inspire confidence, particularly because its call records and tower location information had not been placed in evidence.

Thumb Injury Did Not Establish Participation In The Crime

The accused had a thumb injury and received treatment on September 1, 2011. She explained that her thumb had been crushed in a car door while travelling to Mani Mahesh and voluntarily handed her treatment slip to the police.

The Supreme Court noted that the taxi driver’s statement was recorded after her arrest, when police already knew about the injury and possessed the treatment slip.

In the absence of a satisfactory explanation for how the taxi driver became part of the investigation, the Court considered the possibility that his testimony had been used to construct a narrative connecting the injury to the crime scene.

Since the taxi driver and hotel worker were unreliable, the proved existence of the injury carried little weight in establishing guilt.

Alleged Property Motive Remained Unproved

The prosecution claimed that the accused wanted to eliminate her stepbrother because her father had bequeathed his property to him.

However, no evidence established such a bequest.

The Court also noted that the accused’s father had left five daughters from his first marriage. The accused would therefore not have been the sole person to benefit from the alleged elimination of the stepbrother.

The bench reiterated that absence of motive is not invariably fatal to a prosecution. But where the other circumstances are inconclusive or insufficient, the absence of a proved motive becomes a relevant reason for granting the benefit of doubt.

Complete Chain Of Circumstances Was Missing

The Supreme Court reaffirmed that, in a case resting on circumstantial evidence, the circumstances relied upon must be fully established and must collectively exclude reasonable hypotheses consistent with innocence.

Here, neither the individual incriminating circumstances nor the complete chain required to establish guilt had been proved beyond reasonable doubt.

The Court also reiterated that an acquittal should ordinarily remain undisturbed where it represents a reasonably possible view of the evidence. An appellate court may intervene where convincing evidence has been unjustifiably discarded or the reasoning is perverse, but the mere possibility of another view is insufficient.

Finding that the prosecution had failed to bring home the charge, the Supreme Court dismissed the State’s appeal and upheld the High Court’s acquittal.

Membership Required to Access Case Details & Order Copy

To view the complete Case Details and Download Order Copy, you must have an active membership. Please subscribe to continue.

Read More: GST Council May Unblock ITC On Employee Insurance, Outdoor Catering And Free Samples