Case Name: Babu Sahebagouda Rudragoudar & Others v. State of Karnataka
Case Number: Criminal Appeal No. 985 of 2010
Date of Judgment: April 19, 2024
Quorum: Mehta, J
FACTS OF THR CASE
The case involves an appeal against the acquittal of individuals accused of murdering Malagounda on September 19, 2001. The complainant, Malagounda’s father, claimed to witness the murder along with several servants. Despite multiple alleged eyewitnesses, only Malagounda was injured. The complainant reported the incident at 4 am, but inconsistencies and contradictions arose in witness testimonies. Notably, PW-6 stated the complainant was not present during the attack, contradicting the complainant’s account. Doubts surfaced due to the lack of injuries to other witnesses and discrepancies about where the complaint was lodged. The Medical Jurist’s testimony suggested the death occurred more than 24 hours before the autopsy, conflicting with the reported time of death. Furthermore, heavy rainfall in the area raised questions about the plausibility of the victim being in the field. The defense highlighted a previous murder involving the deceased’s family as a potential motive for false allegations. The High Court’s reliance on weapon recoveries based on accused’s disclosures was deemed inadmissible under Section 27 of the Indian Evidence Act. The appellate court found the trial court’s acquittal justified, noting the High Court improperly interfered without sufficient grounds, affirming the double presumption of innocence in favor of the accused.
ISSUES
- Whether the Accused Were Rightly Acquitted by the Trial Court.
- Whether the High Court Was Justified in Reversing the Acquittal.
- Whether the Weapon Recoveries Were Admissible and Valid.
LEGAL PROVISIONS
- Section 302 of the Indian Penal Code (IPC)
- Section 307 of the Indian Penal Code (IPC)
- Section 27 of the Indian Evidence Act, 1872
- Section 34 of the Indian Penal Code (IPC)
- Section 161 and Section 164 of the Code of Criminal Procedure (CrPC)
CONTENTIONS OF THE APPELLANT
The appellants, in their defense, put forth several contentions challenging the lower court’s decision. Firstly, they argued that the prosecution failed to establish beyond reasonable doubt that they were responsible for the murder of the deceased. They contended that the evidence presented by the prosecution was circumstantial and did not conclusively prove their guilt under Section 302 of the Indian Penal Code (IPC). They highlighted inconsistencies and contradictions in the testimony of key witnesses, which they asserted cast doubt on the veracity of the prosecution’s case. Secondly, the appellants challenged the admissibility of certain statements and evidence under Section 27 of the Indian Evidence Act, 1872. They argued that the statements made by the appellants during police custody were coerced and not voluntary. They further contended that the recovery of weapons allegedly used in the commission of the crime was not supported by independent witnesses or corroborative evidence, thereby raising doubts about its legality and authenticity. Thirdly, the appellants raised procedural irregularities during the investigation and trial stages. They asserted that their rights under Section 161 and Section 164 of the Code of Criminal Procedure (CrPC) were violated during the recording of statements and confessions. They alleged that the police did not follow proper procedures, leading to inconsistencies and discrepancies in the statements recorded, which undermined the reliability of the evidence presented against them.
CONTENTIONS OF THE RESPONDENT
The respondent, representing the State of Uttar Pradesh, presented several contentions in defense of the lower court’s decision. Firstly, they argued that the prosecution had successfully established the guilt of the appellants beyond a reasonable doubt. They emphasized that the circumstantial evidence presented, including eyewitness testimonies and forensic reports, collectively pointed to the culpability of the appellants in committing the murder of the deceased and attempting to murder another individual. Secondly, the respondent contested the appellants’ claim regarding the admissibility of evidence under Section 27 of the Indian Evidence Act, 1872. They asserted that the statements made by the appellants during police custody were voluntary and led to the recovery of crucial evidence, such as weapons used in the crime. They argued that these statements were pivotal in connecting the appellants to the commission of the offense and were obtained in accordance with legal procedures. Thirdly, the respondent refuted the appellants’ allegations of procedural irregularities during the investigation and trial. They contended that the investigation was conducted diligently and in accordance with the provisions of the Code of Criminal Procedure (CrPC). They maintained that any discrepancies or inconsistencies in witness statements were minor and did not undermine the overall credibility of the prosecution’s case.
COURT’S ANALYSIS AND JUDGEMENT
The appellate court began by emphasizing the stringent standard of review in appeals against acquittals. It underscored the dual presumption of innocence benefiting the accused post-acquittal, grounded in the foundational principle of criminal law. The court highlighted the necessity for the appellate tribunal to meticulously reassess both oral and documentary evidence, emphasizing that it should only overturn a lower court’s acquittal if convinced beyond doubt of the accused’s guilt. The court enumerated the grounds justifying the reversal of an acquittal: manifest perversity in the judgment, a lack of scrutiny of essential evidence, or the irrefutably exclusive existence of evidence compellingly supporting the accused’s guilt. It then systematically scrutinized the evidence adduced by the prosecution, identifying contradictions, implausibilities, and discrepancies that cast doubt on its credibility. Moreover, the court scrutinized the evidence provided by the prosecution. It found several inconsistencies and contradictions. For example, the complainant’s presence at the crime scene contradicted the statements of witnesses. Additionally, the timing of the incident was questioned based on the medical evidence presented. There was also a lack of important documents such as the Daily Diary of the police station, which undermined the FIR’s credibility. Furthermore, there were questions about the process of recovering weapons by the investigating officer, which raised doubts about their admissibility as evidence.
In conclusion, after a thorough review of the evidence and consideration of the principles guiding appeals against acquittals, the appellate court upheld the trial court’s decision to acquit the accused. It observed that the trial court’s judgment was reasonable and well-founded, devoid of any apparent defects or perversions. As a result, the appellate court concluded that the High Court’s decision to reverse the acquittal and convict the accused was not justified. It overturned the High Court’s judgment and acquitted the accused of all charges. The court also stated that the accused appellants were on bail and did not need to surrender. Consequently, their bail bonds were released. This judgment underscored the critical need for caution and scrutiny in appellate review of acquittals, reinforcing the presumption of innocence and demanding substantial and compelling evidence to overturn a lower court’s decision.
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Judgement Reviewed by- Shruti Gattani
