DNA Match Alone Not Enough-SC Affirms Aquittal.

⚖️Case Study: State of Himachal Pradesh v. Anchla @ Chanchla

📌Criminal Appeal No. 166 of 2019 | 2026 INSC 1074 | Supreme Court of India | Judgment dated 01.10.2026

📜Facts of the Case

Mithilesh Kumari (deceased No.1) and her minor son Bhupinder Singh (deceased No.2) were found dead inside their locked house at Diur, Himachal Pradesh on 07.09.2011. The prosecution alleged that Anchla @ Chanchla, the stepdaughter of Mithilesh Kumari, had stayed with the deceased on the night of 31.08.2011 and thereafter murdered both victims by strangulation to grab family property allegedly bequeathed in favour of Bhupinder Singh. The case rested entirely on circumstantial evidence.

🧩Legal Issues

1. Whether the prosecution had established an unbroken chain of circumstantial evidence proving the guilt of the accused beyond reasonable doubt.
2. Whether the “last seen together” theory was satisfactorily proved.
3. Whether recovery of keys, mobile phone, and DNA evidence constituted conclusive incriminating circumstances.
4. Whether the High Court’s acquittal warranted interference by the Supreme Court in an appeal against acquittal.

📃Contentions of the Parties

📑State (Appellant)

• The High Court wrongly discarded material evidence.
• DNA evidence matched the accused’s blood with stains found at the crime scene.
• Recovery of keys and deceased’s mobile phone linked the accused to the crime.
• The accused was present at the deceased’s house on 31.08.2011 and was seen with a bleeding thumb injury.
• The High Court’s acquittal was perverse and contrary to evidence.

📑Accused (Respondent)

• The “last seen” evidence was weak and unreliable.
• There was a significant time gap between the alleged last-seen incident and discovery of the dead bodies.
• Recovery evidence was doubtful.
• DNA alone could not establish guilt, especially since she frequently visited the deceased’s house.
• No motive was proved because the alleged bequest in favour of the deceased’s son was never established.

📚Important Case Laws Discussed

1. State of Rajasthan v. Shera Ram @ Vishnu Dutta, (2012) 1 SCC 602

• Held that an appellate court should not interfere with an acquittal unless the findings are perverse or wholly unreasonable.

2. State of Madhya Pradesh v. Bacchudas alias Balram & Ors., (2007) 9 SCC 135

• Reiterated that interference with acquittal is justified only for compelling and substantial reasons where material evidence has been ignored.

3. Rajesh Prasad v. State of Bihar & Anr., (2022) 3 SCC 471

• Summarised circumstances in which the Supreme Court may reverse an acquittal, particularly where the High Court’s reasoning is perverse or causes miscarriage of justice.

4. Hanumant v. State of Madhya Pradesh, (1952) 2 SCC 71 : 1952 SCC OnLine SC 75

• Laid down foundational principles governing conviction based upon circumstantial evidence.

5. Sharad Birdhichand Sarda v. State of Maharashtra, (1984) 4 SCC 116

• Reaffirmed that all circumstances must form a complete chain excluding every hypothesis consistent with innocence.

🔎Observations of the Supreme Court

• The sole “last seen” witness (PW-1) made material improvements over his earlier statement and was not wholly reliable.
• Testimonies of the taxi driver (PW-4) and hotel worker (PW-18) lacked credibility and appeared capable of having been introduced to create a chain of circumstances.
• Investigation suffered from serious lapses, particularly failure to obtain and produce mobile tower location data despite collecting Call Detail Records.
• It was not proved that the lock allegedly opened by recovered keys was the same lock used to secure the house.
• Recovery of keys and mobile phone from the accused was doubtful and lacked convincing evidentiary value.
• DNA evidence merely established that the accused’s blood was present in the house at some point; it did not prove her presence on the date of the murders, especially because she was a regular visitor.
• The prosecution failed to establish motive, as no evidence proved any bequest of property in favour of the deceased’s son.
• The circumstances did not form a complete chain pointing exclusively towards the guilt of the accused.

📋Decision

The Supreme Court held that the prosecution failed to prove the charge of murder beyond reasonable doubt. The High Court’s view was a possible and reasonable view on the evidence. Consequently, the Supreme Court dismissed the State’s appeal and affirmed the acquittal of Anchla @ Chanchla.

💡Key Takeaways

✅ Mere DNA matching is insufficient unless it conclusively connects the accused with the crime.
✅ “Last seen” evidence requires credible corroboration and a proximate timeline.
✅ Investigational lapses, especially non-production of electronic evidence such as tower location records, can seriously weaken the prosecution case.
✅ Recovery evidence must be proved with an unbroken chain of custody and authenticity.
✅ In an appeal against acquittal, the Supreme Court will interfere only when the acquittal is perverse or wholly unsustainable.

📝Conclusion: Suspicion, however strong, cannot replace proof. Since the prosecution failed to establish a complete chain of circumstances excluding every hypothesis of innocence, the benefit of doubt rightly went to the accused.

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📌 Official Copy of judgement 👇