Summary
| Category | Data |
|---|---|
| Court | Supreme Court of India |
| Case Number | Crl.A. No.-002120-002121 – 2024 |
| Diary Number | 3671/2024 |
| Judge Name | HON’BLE MR. JUSTICE VIPUL M. PANCHOLI |
| Bench |
|
| Precedent Value | Binding authority on appeals against acquittal |
| Overrules / Affirms | Affirms existing Supreme Court precedents on appellate restraint in acquittal appeals |
| Type of Law | Criminal Procedure |
| Questions of Law | What is the scope of an appellate court’s power under Section 378 CrPC to interfere with a trial court’s order of acquittal? |
| Ratio Decidendi | The Supreme Court reiterated that while an appellate court may reappreciate both questions of law and fact in an appeal against acquittal, it must guard the double presumption of innocence. It may disturb an acquittal only if (a) the order is patently perverse, (b) it rests on a misreading or non-consideration of material evidence, or (c) no other reasonable inference is possible. Merely because another plausible view exists is not enough to overturn an acquittal. |
| Judgments Relied Upon |
|
| Logic / Jurisprudence / Authorities Relied Upon by the Court | The Court distilled a checklist from this Court’s precedents on the interference threshold in acquittal appeals, emphasising the double presumption of innocence and caution against substituting one plausible view for another. |
| Facts as Summarised by the Court | A missing-person FIR led to charges of conspiracy and murder. The trial court acquitted for lack of a complete chain of circumstances. The High Court re-appreciated evidence, convicted accused, and imposed life sentences. On appeal by accused, the Supreme Court restored the trial court’s acquittal. |
Practical Impact
| Category | Impact |
|---|---|
| Binding On | All subordinate courts adjudicating appeals against acquittal under Section 378 CrPC |
| Persuasive For | High Courts confronted with state appeals against acquittal |
| Follows |
|
What’s New / What Lawyers Should Note
- Clarifies that appellate interference with acquittal requires “patent perversity” or misreading/omission of material evidence, not merely a different plausible view.
- Reaffirms the double presumption of innocence: presumption under Article 14(2) and reinforced by trial-court acquittal.
- Emphasises that “compelling and substantial reasons” must exist to disturb an acquittal.
- Provides a structured checklist for counsel to evaluate the viability of state appeals against acquittals.
Summary of Legal Reasoning
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Scope of Appeal Under Section 378 CrPC
The appellate court has unrestricted power to reappreciate evidence but must exercise restraint due to the double presumption of innocence.
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Precedent Synthesis
Drawing on Chandrappa, Rajesh Prasad, H.D. Sundara, and others, the Court distilled three interference thresholds: patent perversity, misreading/non-consideration of material evidence, and absence of any reasonable alternative conclusion.
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Application to Facts
The High Court’s conviction substituted one reasonable inference for another without identifying any of the three thresholds. Trial court’s acquittal was a plausible view.
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Conclusion
High Court’s reappraisal did not meet the interference threshold; its order was set aside and the trial court’s acquittal restored.
Arguments by the Parties
Petitioners (Accused-Convicts)
- Prosecution failed to prove conspiracy; no meeting of minds or overt act by accused.
- Sole eyewitness (PW-5) unreliable: delayed statement, contradictions, hostility.
- Medical evidence did not support day-of-death theory.
- No recovery witnesses examined; trial court’s view was plausible and should not have been disturbed.
Respondent-State & Informant
- Evidence of voluntary disclosures under Section 27 Evidence Act led to body discovery.
- PW-5’s testimony, though recorded after 21 days, was not shown to be wholly unreliable.
- Post-mortem confirmed manual strangulation.
- Civil-dispute motive and documentary evidence (sale deed) established conspiracy.
Factual Background
Martandagouda went missing on 11 December 2011, prompting an FIR under sections including conspiracy and murder. The trial court acquitted all accused for lack of a complete chain of circumstances. The High Court reversed and convicted on Sections 302, 120-B, 201, 506 IPC read with Section 34. The Supreme Court restored the acquittal, holding that the High Court had substituted its view despite a plausible acquittal rationale.
Statutory Analysis
- Section 378 CrPC (Appeals by the State): The Court emphasised the unqualified power to review acquittals, tempered by appellate restraint doctrines.
- Section 27, Evidence Act: Confession-cum-discovery statements admissible if leading to discovery, but here insufficient to complete the chain of circumstances.
Alert Indicators
- ✔ Precedent Followed