The High Court of Andhra Pradesh reiterates that interference with a trial court’s acquittal is justified only where the findings are manifestly perverse, unreasonable, or based on clear misapplication of law, and not merely because an alternate view is possible. This judgment upholds settled Supreme Court precedent and serves as binding authority on all subordinate courts within Andhra Pradesh in criminal appeals against acquittal.
Summary
| Category | Data |
|---|---|
| Case Name | CRLA/1798/2009 of The State of Andhra Pradesh, rep. by the Public Prosecutor, Vs Katuri Vinodh Kumar |
| CNR | APHC010616542009 |
| Date of Registration | 19-12-2009 |
| Decision Date | 30-10-2025 |
| Disposal Nature | DISMISSED |
| Judgment Author | JUSTICE T. MALLIKARJUNA RAO |
| Court | High Court of Andhra Pradesh |
| Bench | Single Judge Bench (T. MALLIKARJUNA RAO, J.) |
| Precedent Value | Binding authority within Andhra Pradesh; persuasive for other jurisdictions |
| Overrules / Affirms | Affirms settled Supreme Court law regarding limited scope of interference in acquittal appeals |
| Type of Law | Criminal Law, Appellate Procedure |
| Questions of Law | Scope of High Court’s power to interfere with acquittal under Section 378 CrPC; When is interference justified? |
| Ratio Decidendi | The High Court’s power to overturn an acquittal under Section 378 CrPC is circumscribed: interference is warranted only where the trial court’s order is perverse, patently illegal, or based on manifest misappreciation of evidence, leading to miscarriage of justice. Merely because an alternative view is possible, the appellate court will not interfere. The presumption of innocence is reinforced by an acquittal, and the burden on the prosecution to displace that presumption is heightened on appeal. Where the trial court’s view is plausible and not illegal or unreasonable, acquittal must stand. |
| Judgments Relied Upon |
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| Logic / Jurisprudence / Authorities Relied Upon by the Court |
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| Facts as Summarised by the Court | The accused, a motorcycle mechanic, was tried for outraging the modesty of a woman under Section 354 IPC. The complainant alleged that the accused, while drunk, abused and assaulted her at her shop at night. Neighbours reportedly rushed in response to her cries, and the accused fled. An FIR was lodged after a delay. The Sessions Court acquitted the accused citing lack of corroboration, inconsistencies, and unexplained delay. The State appealed. |
Practical Impact
| Category | Impact |
|---|---|
| Binding On | All subordinate courts within Andhra Pradesh |
| Persuasive For | Other High Courts and the Supreme Court |
| Follows |
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What’s New / What Lawyers Should Note
- Reaffirms that High Court interference with trial court acquittal is not permissible unless the acquittal is demonstrably perverse, illegal, or wholly unsupported by the record.
- Unsatisfactory corroboration and unexplained delay in lodging FIR weaken the prosecution’s case and may form valid grounds for acquittal.
- Reinforces that even if the prosecutrix’s testimony stands alone, it must inspire confidence and be free from material inconsistencies to support a conviction.
- Counsel seeking overturn of an acquittal must establish manifest illegality, perversity, or misappreciation of evidence—mere possibility of a different finding is not enough.
- The “two views” principle continues to shield acquittals: where two plausible interpretations exist, the one favourable to the accused must prevail.
Summary of Legal Reasoning
- The Court began by retracing the limits of appellate review in criminal acquittal appeals, relying on Supreme Court rulings (A. Shankar, Sanjay Thakran, Harbeer Singh, Mohan @ Srinivas, State of M.P. v. Kriparan).
- It reaffirmed that interference with an acquittal is justified only if findings are perverse, manifestly illegal, or completely contrary to evidence. Mere alternate plausibility does not suffice.
- The principle that a prosecutrix’s uncorroborated testimony may suffice for conviction was stated (citing Raghubir Singh, Wahid Khan, Rameshwar). However, in this case, the testimony was riddled with inconsistencies and unsupported by independent witnesses—no effort was made to corroborate presence of supposed eyewitnesses.
- The unexplained delay in lodging the FIR (about 36 hours) was found to raise further doubts, referencing Apren Joseph and Kriparan.
- The judgment emphasized that the trial court had carefully considered all the evidence, found material inconsistencies and lack of corroboration, and that its reasoning was plausible and sound.
- Accordingly, no ground existed for the appellate court to overturn the acquittal.
Arguments by the Parties
Petitioner
- Prosecution established all necessary ingredients of the offence under Section 354 IPC.
- Sessions Judge failed to properly appreciate cogent and reliable prosecution evidence.
- Reasons assigned for acquittal are unsustainable.
Respondent
- Supported findings and conclusions of the Sessions Court.
- Highlighted inconsistencies in prosecution evidence, lack of corroboration, and unexplained delay.
Factual Background
The accused, a motorcycle mechanic in Eluru, was alleged to have, in an intoxicated state, outraged the modesty of an unmarried woman running a shop with her mother. The incident allegedly took place late at night; the accused was said to have abused, assaulted, and dragged the complainant toward a dark area, but fled upon intervention by bystanders. The FIR under Section 354 IPC was lodged after a delay of about 36 hours. The Sessions Court acquitted the accused, finding prosecution evidence uncorroborated and inconsistent. The State appealed the acquittal before the High Court.
Statutory Analysis
- Section 378 CrPC (Appeal in case of acquittal): The Court emphasized that an appeal against acquittal is maintainable, but interference by the appellate court is permitted only where the trial court’s finding is perverse, manifestly illegal, or wholly unsupported by the record.
- Section 354 IPC (Assault or criminal force to woman with intent to outrage her modesty): The necessary ingredients and standard of proof required for conviction were considered.
- Section 313 CrPC: The procedural nuances of examination of accused were followed.
- Across all, the Court applied a strict standard: proofs must be beyond reasonable doubt; where doubt survives or alternate plausible view exists, the benefit must go to the accused.
Dissenting / Concurring Opinion Summary
Procedural Innovations
Alert Indicators
- ✔ Precedent Followed – Judgment follows and applies well-established Supreme Court precedents regarding appellate interference with acquittals.