LI Network
Published on: February 14, 2024 at 16:40 IST
The Supreme Court has highlighted the importance of respecting trial Court decisions in cases of acquittal.
The Court stated that if the appellate Court, upon reviewing evidence in an appeal against acquittal, finds two plausible views, the one favoring the innocence of the accused should be adopted.
The Bench, consisting of Justices Bela M. Trivedi and Satish Chandra Sharma, set aside the High Court’s decision that had convicted the accused while overturning the trial court’s acquittal order.
The Court asserted that the High Court should refrain from convicting the accused by reappreciating evidence if the trial court’s view is considered plausible.
The judgment, authored by Justice Satish Chandra Sharma, emphasized the judicially recognized ‘two-views theory,’ stating that when two equally plausible views exist, the controversy should be resolved in favor of the accused.
This not only reinforces the presumption of innocence but also introduces reasonable doubt in the case of the prosecution.
The case in question involved the trial Court acquitting the accused of murder charges under Section 302 of the Indian Penal Code.
The trial Court, after scrutinizing the evidence, concluded that the testimony of Prosecution Witness No. 3 was artificial and unreliable for convicting the accused.
The chain of circumstances, according to the trial court, did not align with the guilt outcome.
Upon the state’s appeal, the High Court re-evaluated the evidence and convicted the accused by disregarding the trial court’s acquittal order.
The accused appealed to the Supreme Court, arguing that the High Court erred in re-evaluating the evidence without identifying any significant faults in the trial court’s decision.
The Court, after hearing arguments from both sides, observed that the High Court had committed an error by re-evaluating the entire evidence.
It stressed that such re-evaluation should be comprehensive and not partial.
The Court outlined three crucial questions the High Court should consider while re-evaluating evidence: whether the trial court thoroughly appreciated the evidence, whether the trial court’s finding was illegal or affected by an error, and whether the trial court’s view was a fairly possible one.
The Supreme Court ultimately set aside the High Court’s conviction order, highlighting the need for a holistic approach in evidence appreciation and the significance of respecting plausible views in cases of acquittal.
CASE TITLE: MALLAPPA & ORS. VERSUS STATE OF KARNATAKA