Rajasthan High Court Upholds Acquittal in Murder Case Due to Contradictory Circumstantial Evidence and Unexplained FIR Delay

State of Rajasthan v. Sampat & Anr., D.B. Criminal Appeal No. 363/2002, decided on 25 February 2026 (Raj HC, Jaipur Bench), reported in 2026:RJ-JP:8788-DB, per Mahendar Kumar Goyal & Sameer Jain, JJ.

(Connected with: Kalyan Ram v. Sampat Singh & Anr., D.B. Criminal Revision Petition No. 674/2001)

The Rajasthan High Court, Jaipur Bench, in D.B. Criminal Appeal No. 363/2002 and connected Criminal Revision Petition No. 674/2001, delivered its judgment on 25.02.2026, dismissing both the appeal filed by the State and the revision petition filed by the complainant. The case arose from Sessions Case No. 23/1999 decided by the Additional District and Sessions Judge, Kishangarh, District Ajmer, wherein the accused persons were acquitted of the charge under Section 302 read with Section 34 IPC.

The prosecution case was based on a written report dated 05.03.1999 submitted by Kalyan Ram, on the basis of which FIR No. 31/1999 was registered at Police Station Rupangarh, District Ajmer, for offences under Sections 302 and 34 IPC. It was alleged that the accused had committed the murder of Rupa Ram. After investigation, a charge-sheet was filed and charges were framed. However, after trial, the learned trial court acquitted the accused, leading to the present appeal and revision before the High Court.

Before the High Court, the State and the complainant argued that the trial court had failed to properly appreciate the circumstantial evidence and that the chain of circumstances clearly established the guilt of the accused. It was submitted that the postmortem report showed an ante-mortem head injury and that a lathi was recovered on the disclosure statement of one of the accused. It was also contended that the delay in lodging the FIR was not fatal to the prosecution case.

On the other hand, the counsel for the accused supported the acquittal and argued that the prosecution evidence was contradictory and unreliable. The High Court carefully examined the evidence on record and noted that the case was entirely based on circumstantial evidence. It found material contradictions in the statements of prosecution witnesses, particularly regarding what the deceased allegedly told them about the incident and who was responsible.

The Court also observed that although the family members claimed to have known about the incident on the same night, the FIR was lodged after a delay of two days by a person who was neither a close family member nor a resident of the same village. No satisfactory explanation for this delay was provided. Further, the medical evidence did not fully support the prosecution version, as only a swelling on the skull was found and there were inconsistencies regarding the alleged dragging of the deceased.

Importantly, the medical evidence suggested the possibility that the deceased might have suffered the fatal injury due to a fall, especially as there was evidence indicating consumption of alcohol. The Court held that the prosecution failed to establish beyond reasonable doubt that the fatal injury was caused by the accused.

In view of these findings, the High Court concluded that the trial court’s judgment of acquittal did not suffer from any perversity, illegality, or infirmity warranting interference in appellate or revisional jurisdiction. Accordingly, both the criminal appeal and the revision petition were dismissed, and the acquittal of the accused was upheld.

By Bhuvnesh Kumar Goyal
Advocate in Jaipur High Court