The Chhattisgarh High Court has reiterated that an appellate court may interfere with an acquittal only when the view taken by the trial court is either “impossible” or “perverse”, following binding Supreme Court authority. If two plausible views are possible, the acquittal must be upheld. This serves as binding precedent on all subordinate courts within the state and persuasive authority elsewhere.
Summary
| Category | Data |
|---|---|
| Case Name | ACQA/1107/2024 of STATE OF CHHATTISGARH Vs SUNIL GUPTA |
| CNR | CGHC010383052024 |
| Date of Registration | 05-11-2024 |
| Decision Date | 15-10-2025 |
| Disposal Nature | DISMISSED |
| Judgment Author | HON’BLE SHRI JUSTICE SANJAY KUMAR JAISWAL |
| Court | High Court Of Chhattisgarh |
| Precedent Value | Binding on subordinate courts in Chhattisgarh; persuasive for other forums |
| Overrules / Affirms | Affirms law as laid down by the Supreme Court |
| Type of Law | Criminal Procedure |
| Questions of Law | What is the permissible scope of appellate interference under Section 378 CrPC in acquittal appeals? |
| Ratio Decidendi | The High Court reaffirmed that appellate interference in acquittal appeals is limited to cases where the trial court’s view is perverse or impossible. If two possible interpretations of evidence exist, the acquittal should not be set aside merely because the appellate court prefers the other. Sporadic contradictions or mere possibility of a different conclusion do not justify interference. The appellate court must only overturn acquittal if the view taken is not at all possible. |
| Judgments Relied Upon | State of Rajasthan vs. Kistoora Ram, 2022 SCC OnLine SC 984 |
| Logic / Jurisprudence / Authorities Relied Upon by the Court | Law laid down by the Hon’ble Supreme Court setting limits on appellate interference in acquittal cases |
| Facts as Summarised by the Court | The accused was prosecuted for offences under IPC Sections 454, 354, 354A and Sections 3(1)(w)(i), 3(2)(vA) of the Scheduled Castes and the Scheduled Tribes (Prevention of Atrocities) Act, 1989. The Sessions Court acquitted the accused. The State preferred an appeal under Section 378 CrPC, challenging the acquittal. Upon review, the High Court found the trial court’s view plausible and supported by evidence on record. |
Practical Impact
| Category | Impact |
|---|---|
| Binding On | All subordinate criminal courts in Chhattisgarh |
| Persuasive For | Other High Courts, Supreme Court |
| Follows | State of Rajasthan vs. Kistoora Ram, 2022 SCC OnLine SC 984 |
What’s New / What Lawyers Should Note
- Reiterates that acquittal can be reversed only if the trial court’s view is “impossible” or “perverse”—not simply because another view is preferred.
- Cites and applies Supreme Court precedent (State of Rajasthan vs. Kistoora Ram, 2022) to emphasize limits on appellate powers.
- Highlights the sanctity of acquittals and the prosecution’s burden in appeal.
Summary of Legal Reasoning
- The High Court began by examining the evidence and reasoning upon which the trial court based the acquittal.
- Referring to the Supreme Court’s decision in “State of Rajasthan vs. Kistoora Ram” (2022 SCC OnLine SC 984), the court articulated the limited scope for interference in acquittal appeals: interference is permissible only if the trial court’s view is “impossible” or “perverse”.
- The court carefully reviewed whether the trial court’s assessment of the evidence was so unreasonable as to be unsustainable. Finding that the trial court’s appreciation of the evidence was plausible and not perverse, the court declined to interfere.
- The High Court emphasized that the mere presence of two possible views is insufficient to overturn acquittal; appellate courts must refrain unless the trial court’s view could not have been taken by any reasonable person on the evidence.
- Ultimately, the High Court found no compelling ground to set aside the acquittal.
Arguments by the Parties
Petitioner (State):
- Contended that the trial court had erred in acquitting the accused.
- Argued that the evidence on record supported conviction under IPC and SC/ST Act provisions.
- Sought that the High Court set aside the acquittal.
Respondent (Accused):
- Supported the trial court’s assessment and acquittal.
- Pointed to contradictions and doubts in the prosecution evidence.
- Argued that the view taken by the trial court was plausible and should not be interfered with.
Factual Background
The prosecution alleged that the accused committed offences under IPC Sections 454 (house-breaking), 354, 354A (outraging modesty), and relevant SC/ST Act provisions. The incident allegedly occurred when the victim was alone at home, and the accused entered and misbehaved. The Sessions Court, after examining the evidence, acquitted the accused. The State of Chhattisgarh appealed the acquittal under Section 378 CrPC. The High Court reviewed the record to assess whether the acquittal was justified.
Statutory Analysis
- Section 378 of the Code of Criminal Procedure, 1973 (CrPC), was the central provision: it governs appeals by the State against orders of acquittal.
- The judgment interpreted Section 378 narrowly—emphasizing, in line with Supreme Court precedent, that appellate interference is only warranted in cases where the trial court’s view is not at all possible or is perverse.
- The court also referenced sections of the IPC and the Scheduled Castes and the Scheduled Tribes (Prevention of Atrocities) Act, 1989, but the central interpretive task was regarding the scope of appellate review under CrPC.
Alert Indicators
- ✔ Precedent Followed – When existing law is affirmed.