Supreme Court restores acquittal in Section 302 IPC murder case, emphasizes higher threshold for reversing trial acquittals

The SC set aside the HC's conviction order and restored the Trial Court's acquittal in a murder case under Section 302 IPC. The SC held that the HC erred in reversing the acquittal without finding illegality or perversity in the Trial Court's reasoning. The evidence lacked conclusive circumstances, particularly regarding a witness's unexplained conduct during the night of the incident. The SC emphasized that conviction requires proof that the accused "must have" committed the offense, not "may have," and that the presumption of innocence gets strengthened after acquittal, requiring a higher threshold for reversal in appeal.

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Issues Involved:

1. Credibility of eyewitnesses (PW-3 and PW-4).
2. Legality of the High Court's re-appreciation of evidence.
3. Applicability of principles of circumstantial evidence.

Summary:

Issue 1: Credibility of Eyewitnesses (PW-3 and PW-4)

The Trial Court acquitted the accused, finding the evidence of eyewitness PW-3 not worthy of credit and his conduct after the alleged murder artificial. The High Court, however, re-appreciated the evidence and found the testimonies of PW-3 and PW-4 credible, leading to the conviction of the appellants. The Supreme Court noted that PW-3's conduct was dubious as he did not inform anyone about the incident for 18 hours, did not seek medical help for PW-4, and his presence at the scene was doubtful. PW-4's testimony was also found inconsistent with the medical evidence, raising doubts about his credibility.

Issue 2: Legality of the High Court's Re-appreciation of Evidence

The Supreme Court emphasized that while the High Court has the power to re-appreciate evidence, it must do so thoroughly and address all reasons given by the Trial Court for acquittal. The High Court failed to demonstrate any illegality, error of law, or fact in the Trial Court's decision. The Supreme Court reiterated that if two views are possible, the one in favor of the accused should be followed, and the High Court's reversal of acquittal was not justified as it was based merely on a difference of opinion without addressing the detailed reasoning of the Trial Court.

Issue 3: Applicability of Principles of Circumstantial Evidence

The Supreme Court noted that in the absence of credible direct evidence, the case falls back on circumstantial evidence, which must form a complete chain pointing towards the guilt of the accused. The prosecution failed to establish this chain conclusively. The contradictions between oral testimonies and medical reports, failure to seize essential materials, and discrepancies in the timeline further weakened the prosecution's case.

Conclusion:

The Supreme Court found that the High Court erred in reversing the acquittal without finding any illegality or error in the Trial Court's reasoning. The Trial Court's view was legally permissible, and the High Court's decision was not justified. The Supreme Court set aside the High Court's judgment, restored the Trial Court's order of acquittal, and directed the release of the appellants.

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