Appellate interference with acquittal under Article 136 restored conviction where evidence was perversely appreciated

Under Article 136, the SC may interfere with an acquittal where the appreciation of evidence is perverse, ignores vital material, or causes miscarriage of justice. Applying that standard, the acquittal of Gurpreet Singh was set aside because the complainant and eyewitness evidence was found natural and trustworthy, corroborated by prompt reporting, proved motive, and recovery of the weapon; the High Court's rejection of this evidence was based on misreading of the record. The acquittal of the co-accused was upheld because their names were absent from the earliest version, the eyewitnesses did not know them, and no convincing material showed participation or conspiracy.

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Issues: (i) Whether interference with the acquittal of Gurpreet Singh was warranted under Article 136 of the Constitution of India; (ii) Whether the acquittal of the co-accused was sustainable.

Issue (i): Whether interference with the acquittal of Gurpreet Singh was warranted under Article 136 of the Constitution of India

Analysis: The presumption of innocence stands reinforced after acquittal, and interference is ordinarily limited. However, interference is justified where the acquittal rests on a perverse appreciation of evidence, ignores vital material, or results in miscarriage of justice. The evidence of the complainant and the eyewitness was found to be natural and trustworthy, their presence at the scene was corroborated by a prompt report, the motive was proved, and the recovery of the weapon further supported the prosecution case. The reasons adopted by the High Court to discard this evidence were held to be untenable and based on misreading of the record.

Conclusion: The acquittal of Gurpreet Singh was not sustainable and was set aside; the conviction and sentence recorded by the Trial Court were restored.

Issue (ii): Whether the acquittal of the co-accused was sustainable.

Analysis: The names of the co-accused were not disclosed in the earliest version, the eyewitnesses did not know them, their later nomination was unexplained, and no convincing material showed their participation or conspiracy. In these circumstances, the view taken by the High Court in extending the benefit of doubt was found to be a possible and plausible view on the evidence.

Conclusion: The acquittal of the co-accused was upheld.

Final Conclusion: The appeals succeeded only to the extent of restoring the conviction of Gurpreet Singh, while the acquittal of the remaining accused was maintained.

Ratio Decidendi: An appellate court may interfere with an acquittal under Article 136 where the High Court's appreciation of evidence is perverse or results in miscarriage of justice, but a plausible acquittal based on benefit of doubt will not be disturbed.

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