The Chhattisgarh High Court reaffirms that appellate interference with acquittal under Section 378 CrPC is justified only when the trial court’s view is not a “possible” one, strengthening the double presumption of innocence for acquitted accused. This judgment relies on established Supreme Court authority and clarifies binding standards for criminal appeals by the State.
Summary
| Category | Data |
|---|---|
| Case Name | ACQA/115/2015 of State Of Chhattisgarh Vs Dharam Singh Yadav |
| CNR | CGHC010008112015 |
| Date of Registration | 23-07-2015 |
| Decision Date | 28-10-2025 |
| Disposal Nature | DISMISSED |
| Judgment Author | HON’BLE SHRI JUSTICE RADHAKISHAN AGRAWAL |
| Court | High Court of Chhattisgarh |
| Precedent Value | Binding within territorial jurisdiction; clarificatory on appellate standards |
| Overrules / Affirms | Affirms principles in Jafarudheen v. State of Kerala (2022) 8 SCC 440 |
| Type of Law | Criminal law; procedure relating to appeal against acquittal under Section 378 CrPC |
| Questions of Law | What is the threshold for appellate court interference in an acquittal appeal, particularly regarding the “possible view” standard and presumption of innocence? |
| Ratio Decidendi |
The High Court held that in appeals against acquittal under Section 378 CrPC, interference is warranted only if the trial court’s view is not a “possible view,” especially given the reinforced presumption of innocence after acquittal. The double presumption operates in favour of the accused, and reversal of acquittal must be based on thorough scrutiny per established legal parameters. In the present case, inconsistencies and failure to prove material aspects beyond reasonable doubt meant the acquittal could not be disturbed. The High Court found the trial court’s view to be reasonable and just, declining to interfere. |
| Judgments Relied Upon | Jafarudheen v. State of Kerala (2022) 8 SCC 440 |
| Logic / Jurisprudence / Authorities Relied Upon by the Court |
|
| Facts as Summarised by the Court | Incident on 26.03.2014 involving alleged criminal trespass, threat, and outraging of modesty against a Scheduled Caste woman; prosecution evidence marked by inconsistencies and delayed FIR; trial court acquitted accused of IPC and SC/ST Act charges; State appealed. |
Practical Impact
| Category | Impact |
|---|---|
| Binding On | All subordinate courts within Chhattisgarh |
| Persuasive For | Other High Courts and criminal appellate benches across India |
| Follows | Jafarudheen v. State of Kerala (2022) 8 SCC 440 |
What’s New / What Lawyers Should Note
- The judgment reaffirms and clarifies the binding standard that appellate courts may not interfere with acquittals unless the trial court’s view is not merely possible but perverse or wholly unsupported by evidence.
- Stresses the “double presumption of innocence” after an acquittal, making reversal even less likely.
- Lawyers should note the emphasis on the need for cogent, consistent evidence to justify overturning an acquittal, especially where key witnesses are not examined or there is unexplained delay in FIR.
- Highlights that failure to establish the statutory status of the victim (e.g., SC/ST status under the relevant Act) can fatally undermine the prosecution’s case under special statutes.
Summary of Legal Reasoning
- The High Court reviewed the inconsistencies in the testimonies of the main witnesses, including contradictions on physical access to the premises and the relationship between the parties.
- Noted the absence of examination of material witnesses (the prosecutrix’s husband and the constable who responded immediately post-incident).
- Observed the unexplained delay in lodging the FIR and lack of adequate explanation for the injury.
- Cited and applied the Supreme Court decision in Jafarudheen v. State of Kerala, reiterating that the double presumption of innocence after acquittal should guide appellate approach, and the trial court’s view should be respected if it can be termed “possible.”
- Considered the evidentiary failure to prove the prosecutrix’s SC status as per statutory requirement.
- Held that, overall, the prosecution failed to establish guilt beyond reasonable doubt, so the appellate court would not interfere with acquittal.
Arguments by the Parties
Petitioner
- Argued that the trial court’s acquittal was perverse and illegal.
- Asserted that the evidence, especially the testimony of the prosecutrix, clearly established the accused’s guilt.
- Claimed grave error by the trial court in disregarding clear and reliable prosecution evidence.
Respondent
No appearance; no submissions recorded.
Factual Background
On 26 March 2014, at around 11:45 p.m., the prosecutrix, a Scheduled Caste woman, alleged that the accused unlawfully entered her premises and attempted to outrage her modesty. The accused was reportedly familiar with the victim and her family. An FIR was lodged the next day. Medical examination and witnesses’ testimonies were gathered. The trial court subsequently acquitted the accused of all IPC and SC/ST Act charges. The State challenged this acquittal in the High Court.
Statutory Analysis
- Section 378 CrPC: Discussed in relation to the conditions under which appellate courts can interfere with acquittals; applied the “possible view” doctrine and double presumption of innocence.
- Section 3(1)(c-ii) of SC/ST (Prevention of Atrocities) Act, 1989: Requirement that victim be proven to be member of SC/ST under applicable law in State; held that a caste certificate from another state does not automatically confer legal status in Chhattisgarh.
- Relevant Indian Penal Code Sections: 457, 354, 354(d), 323, 506 – discussed in context of standard for conviction on such charges.
Alert Indicators
- ✔ Precedent Followed – When existing law is affirmed.