The High Court reaffirmed that an appellate court should not interfere with a trial court’s acquittal unless the acquittal is manifestly unreasonable or unsupported by the evidence. This decision upholds existing precedent and serves as binding authority in criminal appeals involving similar evidentiary issues, particularly when prosecution evidence is contradictory or unreliable.
Summary
| Category | Data |
|---|---|
| Case Name | ACQA/335/2018 of STATE OF CHHATTISGARH Vs SUNIL SINGH |
| CNR | CGHC010273952018 |
| Date of Registration | 30-08-2018 |
| Decision Date | 02-09-2025 |
| Disposal Nature | DISMISSED |
| Judgment Author | HON’BLE SHRI JUSTICE RADHAKISHAN AGRAWAL |
| Court | HIGH COURT OF CHHATTISGARH AT BILASPUR |
| Precedent Value | Binding on subordinate courts in Chhattisgarh; persuasive for other High Courts |
| Type of Law | Criminal Procedure |
| Questions of Law |
|
| Ratio Decidendi |
The appellate court must not interfere with an acquittal unless the decision is unreasonable or not based on evidence. The trial court’s assessment of evidence, including contradictions and reliability of witnesses, is given primacy. In this instance, significant contradictions in the prosecution’s case, hostile and unexamined witnesses, and the absence of corroborative evidence justified the acquittal. The trial court’s findings were found to be proper and grounded in the record, warranting no interference. |
| Logic / Jurisprudence / Authorities Relied Upon by the Court |
|
| Facts as Summarised by the Court |
The accused was acquitted of Sections 294, 506-B, 323 & 324 IPC after the trial court found contradictions in the complainant’s testimony, hostile and unexamined key witnesses, and no corroborative medical or seizure evidence. The appeal by the State sought to overturn this acquittal. |
| Citations | 2025:CGHC:44909 |
Practical Impact
| Category | Impact |
|---|---|
| Binding On | All subordinate courts in Chhattisgarh |
| Persuasive For | Other High Courts |
What’s New / What Lawyers Should Note
- Reaffirms that an appellate court will not interfere with an acquittal unless the verdict is perverse, manifestly erroneous, or against the weight of evidence.
- Highlights the importance of corroboration and consistency in prosecution evidence for reversing an acquittal.
- Underscores the weakness of the prosecution case when witnesses are not examined, or turn hostile, and medical evidence is unsupportive.
- Lawyers should emphasize contradictions and lack of corroboration to defend acquittals on appeal.
Summary of Legal Reasoning
- The High Court closely analyzed the evidence, noting major contradictions between the complainant’s FIR and oral testimony regarding the place and manner of the incident.
- The primary prosecution witnesses either turned hostile or were not examined at all, significantly weakening the prosecution case.
- The medical examiner confirmed only simple injuries and admitted the injuries could be self-inflicted; no weapon was provided for examination.
- The trial court’s reliance on the lack of credible, corroborative evidence and its evaluation of witness credibility was endorsed.
- The appellate power to overturn an acquittal is limited; acquittal stands unless findings are manifestly contrary to evidence or grossly unreasonable.
- Accordingly, the appeal was dismissed, upholding the acquittal.
Arguments by the Parties
Petitioner (State):
- Judgment of acquittal is contrary to law.
- Evidence shows active participation of the accused, including assault and seizure of weapon.
- Medical evidence corroborates the occurrence of injuries.
- Trial court erred in appreciating evidence and acquitting the accused.
Respondent (Accused):
- Judgment of acquittal is proper due to material contradictions and omissions in prosecution evidence.
- Contradictory/doubtful place of incident and unexamined eyewitnesses.
- Key seizure witness turned hostile and did not support prosecution.
- No clinching evidence exists; acquittal should not be interfered with.
Factual Background
An FIR was lodged by Uday Singh against his nephew Sunil Singh, alleging assault with a blade and abuse. The incident was purportedly witnessed by several individuals, though not all were examined at trial. The medical evidence showed only simple injuries, and seizure witnesses failed to support the prosecution. The trial court acquitted the accused due to contradictions and lack of reliable corroboration. The State appealed against this acquittal.
Statutory Analysis
- The High Court analyzed Section 378(1) of the Code of Criminal Procedure, 1973, concerning the State’s right to appeal an acquittal.
- The offence sections considered were 294, 506-B, 323 & 324 of the Indian Penal Code.
- No further interpretative analysis of statutory provisions is mentioned in the judgment.
Alert Indicators
- Precedent Followed – The High Court reaffirmed established law regarding non-interference with reasoned acquittals by the trial court.
Citations
- 2025:CGHC:44909 (Neutral citation)
- NAFR (Not Approved For Reporting)