Failure to maintain a continuous chain of custody for seized biological samples vitiates an order of conviction.

The State of Madhya Pradesh appealed against the judgment dated December 16, 2022, passed by the JMFC, Umaria, which acquitted the respondent of charges under Sections 9 and 39 r/w 51 of the Wild Life Protection Act, 1972.

The prosecution alleged that on October 26, 2012, Forest Department officials intercepted the accused, who confessed to killing a wild boar with pig-killing bombs to fund his wife's treatment.

Officials allegedly recovered 66 bombs and wild boar meat/parts from his possession.

Independent witnesses turned hostile, and discrepancies emerged regarding the nature of the seized material (pork vs. intestine vs. stomach) and the lack of immediate sealing of evidence.

1. Whether the trial court's acquittal was perverse or based on a misreading of material evidence, specifically regarding the chain of custody of the seized animal remains.

2. Whether the appellate court should interfere with an order of acquittal when a plausible view in favor of the accused exists.

Leave to appeal against acquittal under Section 378(3) of the CrPC.

The appellate court should not overturn an acquittal if the trial court’s view is "possible" and legally plausible as per H.D. Sundara v. State of Karnataka (2023).

The presumption of innocence is strengthened by an acquittal and interference is only permitted in cases of patent perversity or error of law as established in Babu Sahebagouda Rudragoudar v. State of Karnataka (2024) and Mallappa v. State of Karnataka (2024).

Substantive provisions of Sections 9, 39, and 51 of the Wild Life Protection Act, 1972.

The High Court found multiple failures in the prosecution's case: no documented record of the initial tip-off and material contradictions between departmental witnesses (PW-1 and PW-2) regarding what was actually seized.

The court noted a breach in the chain of custody as the seized material was not sealed at the spot.

The veterinary expert (PW-8) admitted the material was not in a sealed condition when received and was sent back for 4-5 days to dry, during which time it remained unsealed and vulnerable to tampering.

No draft or proof was provided for the dispatch of samples to the Forensic Cell in Dehradun, rendering the resulting forensic report (Ex. P/20) unreliable.

The Court concluded that since the view taken by the trial court—that the accused was entitled to the benefit of the doubt due to these procedural lapses—was a possible and reasonable view, there was no ground for interference.

The application for leave to appeal (I.A. No. 10140/2023) was dismissed, and the acquittal of Golu Singh was upheld.