When Can an Appellate Court Overturn a Trial Court’s Acquittal Under Criminal Procedure?

Summary

Practical Impact

What’s New / What Lawyers Should Note

• Reaffirms that appellate interference in acquittal cases demands patent perversity or misreading of evidence, not merely the possibility of another view.
• Emphasises the double presumption of innocence: once acquitted, an accused’s innocence is further reinforced.
• Clarifies that “compelling and substantial reasons” are required to disturb a plausible trial-court finding.
• Underscores that an appeal against acquittal under Section 378 CrPC carries no statutory fetters but must respect reasonable trial-court conclusions.
• Confirms that even cogent motive or confession evidence cannot fill gaps in an unbroken chain of circumstances.

Summary of Legal Reasoning

1. Reliability of Evidence
   • Trial court found the sole eyewitness unreliable (delayed 21‐day disclosure, hostility, criminal antecedents) and medical opinion inconsistent with prosecution theory.
   • Confessional statements under Section 27 Evidence Act and discovery of the body lacked independent corroboration.
2. Chain of Circumstances
   • Prosecution failed to establish an unbroken chain pointing exclusively to guilt—motive was speculative, no direct last‐seen proof, and key witnesses not examined.
3. Scope of Appeal Against Acquittal
   • Appellate court may reappreciate evidence fully but must not overturn acquittal if another reasonable view exists.
   • Interference justified only if acquittal is patently perverse, based on omission/misreading of material evidence, or if guilt is the only conclusion possible.
4. Application of Precedents
   • Followed Chandrappa, Rajesh Prasad, H.D. Sundara, Ramesh, Basappa, and Babu Sahebagouda Rudragoudar to articulate the “compelling reasons” test.
5. Conclusion
   • High Court’s reversal of a plausible trial‐court acquittal lacked the required compelling reasons and hence was set aside.

Arguments by the Parties

Petitioner

• Conspiracy elements (meeting of minds, concerted action) not proved; suspicion cannot substitute proof.
• Sole eyewitness (PW-5) delayed disclosure, contradicted earlier statements, had criminal antecedents—unreliable.
• Medical evidence did not support prosecution timeline.
• Trial court’s view was plausible; High Court should not have disturbed acquittal merely because it preferred another view.

Respondent

• Eyewitness and confession statements under Section 27 Evidence Act led to discovery of the body—admissible and reliable.
• Medical opinion corroborates manual strangulation.
• Civil‐dispute motive, post-FIR sale deed and tenancy disputes established conspiracy and motive.
• High Court properly reappreciated evidence and found only guilt conclusion possible.

Factual Background

Between 11 and 16 December 2011, a man went missing and his son lodged a missing-person FIR. Investigation unearthed alleged land‐dispute animus against four accused, leading to charges under IPC Sections 302, 120-B, 201, 506 read with Section 34. The trial court acquitted for lack of proof, the High Court convicted on reappreciation of motive, confession and discovery of the body, and the Supreme Court restored the acquittal as the trial-court view was plausible.

Statutory Analysis

• Indian Penal Code, 1860: Sections 302 (murder), 120-B (criminal conspiracy), 201 (causing disappearance of evidence), 506 (criminal intimidation), read with Section 34 (common intention).
• Code of Criminal Procedure, 1973: Appeal against acquittal under Section 378—appellate court’s power to review evidence without statutory restriction, subject to the “two‐views” principle.
• Indian Evidence Act, 1872: Section 27—admissibility of confession or disclosure leading to discovery of fact or object.

Alert Indicators

• ✔ Precedent Followed – upholds established test for interference in acquittal appeals under CrPC