Practical Implications for Stakeholders
For Investigating Officers
Investigating officers must meticulously maintain malkhana records, document every movement of seized articles, and ensure that forwarding letters and seals are in order before dispatch to FSL; any unexplained returns or discrepancies can render key forensic evidence unusable at trial. They must also ensure timely and proper procurement of Section 65-B certificates from service providers when relying on CDRs, messages, or other electronic records.[1]
For Prosecutors
Prosecutors need to scrutinise link evidence and procedural compliance before relying heavily on recoveries and forensic reports, especially in circumstantial evidence cases where such material often forms the backbone of the prosecution story. They should insist on production and proof of Section 65-B certificates and be prepared to address chain-of-custody questions through appropriate witnesses and documents.[1]
For Defence Counsel
Defence counsel can draw on this judgment to challenge the reliability of recoveries that are internally inconsistent or poorly documented, as well as to attack forensic evidence where the chain of custody is shaky or unexplained gaps exist. The ruling also provides strong support for objections to the admissibility of electronic evidence in the absence of a compliant Section 65-B certificate, and for reminding courts that reverse-burden provisions like Section 106 Evidence Act cannot be invoked to plug foundational gaps in the prosecution case.[1]
For Trial Courts
Trial courts are encouraged to adopt a critical stance towards circumstantial evidence, carefully verifying that each circumstance is (a) proved by admissible and credible material, and (b) logically integrated into a complete chain before recording a conviction. They must also strictly apply the statutory requirements of Section 65-B and chain-of-custody principles, avoiding the temptation to treat procedural lapses as mere technicalities when they go to the heart of evidentiary reliability.[1]
Conclusion
Pooranmal v. State of Rajasthan serves as a timely reminder that the criminal justice system’s commitment to fairness and due process demands strict adherence to evidentiary rules, particularly in cases where the entire edifice rests on circumstantial and technical evidence. By setting aside a long-standing conviction on the grounds of unreliable recoveries, broken chain of custody, and inadmissible electronic records, the Supreme Court has reinforced the principle that it is better that suspicion, however grave, should not replace proof in depriving a person of liberty.[1]
