I'm a believer in the heavier bullet, Federal 158 gr +P lead hollow point. My thinking is that if it doesn't expand (velocities in a .38 snub nose are rather pedestrian and may or may not expand) it will give adequate penetration.
It also has a stellar reputation in actual gunfights for stopping power.
A close second choice would be the Speer 135 gr Gold Dot. Either will get the job done if YOU do your job. Bullet placement, bullet placement, bullet placement - that equates to practice, practice, practice...
YMMV
Dale53