Appeal against acquittal: credible corroborated eyewitness evidence and a perverse trial view justified reversal of acquittal.
In an appeal against acquittal, interference is justified only where the trial court's view is patently erroneous, perverse, or demonstrably unsustainable; where two reasonable views are possible, the view favouring acquittal ordinarily prevails. Applying that standard, the High Court was found justified in reversing the acquittal because the trial court had assessed the evidence inconsistently and relied on immaterial contradictions, while the prosecution case was supported by eyewitnesses, injured witnesses, independent witnesses, medical evidence, and forensic material. Mere membership of a rival union did not, by itself, make eyewitnesses unreliable when their presence and testimony were otherwise consistent and corroborated. The conviction was therefore upheld.
Issues: (i) Whether the High Court was justified in reversing the trial court's acquittal and convicting the appellants on the evidence adduced; (ii) whether the eyewitness testimony could be rejected as unreliable merely because the witnesses belonged to a rival union.
Issue (i): Whether the High Court was justified in reversing the trial court's acquittal and convicting the appellants on the evidence adduced.
Analysis: In an appeal against acquittal, interference is warranted only when the trial court's approach is patently erroneous, its conclusions are wholly untenable, or its findings are demonstrably unsustainable. If two reasonable views are possible on the evidence, the view favouring acquittal must prevail. On the record, the trial court had assessed the evidence in an isolated and inconsistent manner, placed undue reliance on immaterial contradictions, and reached conclusions that were not reasonably supportable. The eyewitness account was corroborated by injured witnesses, independent witnesses, medical evidence, and forensic material showing explosive substance. The High Court, therefore, was justified in interfering with the acquittal.
Conclusion: The reversal of acquittal and the conviction recorded by the High Court were upheld.
Issue (ii): Whether the eyewitness testimony could be rejected as unreliable merely because the witnesses belonged to a rival union.
Analysis: Mere membership of a rival group does not, by itself, discredit eyewitnesses whose presence at the scene is established and whose testimony remains consistent, unshaken in cross-examination, and supported by other evidence. The fact that some witnesses belonged to the complainant group did not render them unworthy of credit, especially when injured witnesses were among them and their account was corroborated by neutral witnesses and medical evidence. The alleged rivalry was not sufficient to discard the prosecution version.
Conclusion: The eyewitness evidence was rightly accepted and could not be discarded on the ground of union rivalry alone.
Final Conclusion: The appeal failed because the trial court's acquittal was found to be unsustainable and the High Court's conviction was affirmed.
Ratio Decidendi: In an appeal against acquittal, interference is justified only where the trial court's view is patently illegal, perverse, or demonstrably unsustainable; mere existence of an alternative view is not enough, and credible eyewitness evidence corroborated by medical and forensic material cannot be rejected solely on the ground of group rivalry.
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