A) Abstract / Headnote

The case involves the reversal of a trial court’s acquittal by the High Court, which convicted three appellants (Accused Nos. 3, 4, and 5) for the murder of one Marthandappa. The Supreme Court restored the acquittal, emphasizing the presumption of innocence and the High Court’s failure to demonstrate illegality or perversity in the trial court’s judgment. The prosecution relied heavily on testimonies of PW-3 (an alleged eyewitness) and PW-4 (the injured witness). However, inconsistencies in their testimonies, coupled with doubts regarding credibility, led to the dismissal of the High Court’s findings. The Supreme Court reiterated principles governing appellate review of acquittals, highlighting the significance of the two-views theory and the importance of holistic evidence appreciation.

Keywords: Acquittal, Presumption of Innocence, Two-views Theory, Credibility, Chain of Circumstances, Reappreciation of Evidence.

B) Case Details

i. Judgement Cause Title: Mallappa & Ors. v. State of Karnataka
ii. Case Number: Criminal Appeal No. 1162 of 2011
iii. Judgement Date: 12 February 2024
iv. Court: Supreme Court of India
v. Quorum: Bela M. Trivedi and Satish Chandra Sharma, JJ.
vi. Author: Justice Satish Chandra Sharma
vii. Citation: [2024] 2 S.C.R. 288; 2024 INSC 104
viii. Legal Provisions Involved:

• Section 302, Indian Penal Code, 1860
• Code of Criminal Procedure, 1973
  ix. Judgments Overruled by the Case: High Court of Karnataka’s reversal of acquittal (CRLA No. 1363 of 2005).
  x. Case is Related to Which Law Subjects: Criminal Law, Evidence Law, Appellate Jurisprudence.

C) Introduction and Background of Judgement

The appellants, Mallappa (A3), Hanamanth (A4), and Dharamanna (A5), were acquitted by the trial court for the alleged murder of Marthandappa. The High Court overturned this acquittal based on reappreciation of evidence, convicting them under Section 302 IPC. The Supreme Court examined whether the High Court was justified in reversing the acquittal. The appeal raised significant issues about the scope of appellate power, the standard for reversing acquittals, and the evaluation of witness credibility.

D) Facts of the Case

• Marthandappa (deceased) allegedly had an illicit relationship with the wife of Accused No. 5, straining relations between him and the accused.
• On 28 June 1997, while traveling with PW-3 and PW-4 in a bullock-cart, the deceased was attacked by eight accused persons near Shantpur.
• The accused used axes, knives, and clubs to assault the deceased and PW-4. PW-3 claimed to have witnessed the incident while hiding.
• PW-4 was injured and admitted to a hospital a day later. The deceased succumbed to injuries.
• The trial court acquitted all accused, finding the testimonies of PW-3 and PW-4 unreliable. The High Court reversed the acquittal for A3, A4, and A5, convicting them of murder.

E) Legal Issues Raised

1. Whether the High Court erred in reversing the trial court’s acquittal of the appellants.
2. Whether the testimonies of PW-3 and PW-4 were credible and consistent with the medical evidence.
3. Whether the High Court’s reappreciation of evidence satisfied the standard for overturning an acquittal.

F) Petitioner/Appellant’s Arguments

1. Presumption of Innocence: The appellants argued that acquittals strengthen the presumption of innocence, requiring higher standards to reverse.
2. Flaws in Witness Testimonies: The appellants highlighted inconsistencies in the accounts of PW-3 and PW-4, particularly regarding timelines, injuries, and post-incident conduct.
3. Procedural and Evidentiary Gaps: The prosecution failed to establish a consistent chain of circumstances. Medical reports and timelines contradicted the witness statements.
4. No Illegality in Trial Court’s Order: The trial court’s findings were plausible and based on a detailed appreciation of evidence.

G) Respondent’s Arguments

1. Credibility of Witnesses: The prosecution defended the reliability of PW-3 and PW-4, emphasizing that one was an eyewitness and the other an injured witness.
2. Reappreciation of Evidence: The High Court was within its rights to reassess evidence to prevent miscarriage of justice.
3. Motive and Opportunity: The prosecution argued that strained relations and the presence of the accused established guilt.

H) Related Legal Provisions

• Section 302, IPC: Punishment for murder.
• Code of Criminal Procedure, 1973: Governs appellate powers and the standards for reappreciation of evidence in acquittal appeals.

I) Judgement

a. Ratio Decidendi

1. Presumption of Innocence: The Supreme Court emphasized that acquittals reinforce the presumption of innocence, necessitating strong reasons for reversal.
2. Two-views Theory: If two views emerge from evidence, the view favoring the accused must prevail.
3. High Court’s Error: The High Court failed to identify any illegality, perversity, or error in the trial court’s findings.

b. Obiter Dicta

1. Witness Credibility: The inconsistent behavior and delayed reporting by PW-3 and PW-4 undermined their testimonies.
2. Medical Contradictions: Discrepancies in injury descriptions and timelines raised doubts about the prosecution’s case.

c. Guidelines

1. Appellate Review of Acquittals:

   • Comprehensive evidence appreciation is mandatory.
   • The appellate court must address trial court findings in detail.
   • Conviction requires demonstrating errors in the trial court’s judgment.

2. Witness Testimonies:

   • Testimonies must align with medical and circumstantial evidence.
   • The burden of proof lies with the prosecution to establish credibility.

J) Conclusion & Comments

The Supreme Court restored the trial court’s acquittal, reaffirming principles of criminal jurisprudence. The case underscores the sanctity of acquittals and the rigorous standards required for their reversal.

K) References

a. Important Cases Referred

1. Selvaraj v. State of Karnataka [(2015) 10 SCC 230].
2. Sanwat Singh v. State of Rajasthan [(1961) 3 SCR 120].
3. Sharad Birdhichand Sarda v. State of Maharashtra [(1984) 4 SCC 116].

b. Important Statutes Referred

1. Indian Penal Code, 1860
2. Code of Criminal Procedure, 1973