Acquittal affirmed where contradictory testimony and medical evidence failed to establish guilt beyond reasonable doubt.

The appellant, the original complainant, alleged that on 25 November 2013, while working at the “Agri Business Center” near Inaj village, the respondent-accused formed an unlawful assembly, assaulted him with an axe, iron pipes, fists and kicks, used caste-abusive words, and threatened him.

An FIR was registered for offences under Sections 506(2), 504, 324, 323, 149, 148, 147 and 114 of the IPC, Section 135 of the Gujarat Police Act, and Section 3(1)(x) of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989.

After investigation and committal, the accused were tried in Atrocity Sessions Case No. 4 of 2014. The trial court acquitted all accused by judgment dated 20 October 2015.

The complainant challenged the acquittal under Section 378 of the Code of Criminal Procedure, 1973.

The prosecution relied on the complainant, his wife and other witnesses, medical evidence, injury certificates, the scene panchnama, the FIR, and other documentary material.

1. Whether the trial court was justified in acquitting the accused of the alleged IPC, Gujarat Police Act and Atrocities Act offences?

2. Whether the trial court correctly appreciated the oral and documentary evidence led by the prosecution?

3. Whether the acquittal suffered from illegality, irregularity, perversity or any other infirmity warranting appellate interference?

The court applied Section 378 CrPC governing appeals against acquittal and the prosecution’s burden to prove the charged offences beyond reasonable doubt under the IPC, Section 135 of the Gujarat Police Act and Section 3(1)(x) of the SC/ST (Prevention of Atrocities) Act, 1989.

It reiterated that an appellate court has full power to review and reappreciate evidence in an acquittal appeal, but must bear in mind the accused’s double presumption of innocence; where two reasonable views are possible, the acquittal should not ordinarily be disturbed.

These principles were drawn from Chandrappa v. State of Karnataka, (2007) 4 SCC 415, as reaffirmed in Rajesh Prasad v. State of Bihar, (2022) 3 SCC 471, Babu Sahebagouda Rudragoudar v. State of Karnataka, AIR 2024 SC 2252; (2024) 8 SCC 149, and Ramesh v. State of Karnataka, (2024) 9 SCC 169.

Interference is justified only where the trial court’s approach is manifestly illegal, unreasonable or perverse, or where material evidence has been ignored.

The High Court found that the prosecution evidence did not reliably establish the alleged assault or the participation and individual roles of the accused beyond reasonable doubt.

Although the complainant attributed specific weapons and acts to different accused, his evidence was affected by admitted prior animosity and a possible counterblast arising from an earlier quarrel between the two groups.

The medical evidence materially contradicted the prosecution version: the Junagadh doctor found only simple injuries, no fracture or significant external injury, a normal CT scan, and no history involving an axe or pipes; the injuries could also have resulted from a fall or accident.

The wife’s testimony contained material inconsistencies regarding the complainant’s location, the manner of the incident, his condition and the presence of the accused, and was regarded as exaggerated and unsupported by independent evidence.

In light of these contradictions, the absence of corroboration, the admitted hostility between the parties and the strengthened presumption of innocence following acquittal, the High Court held that the trial court’s view was a reasonable one and not perverse or legally infirm.

It held that the prosecution had failed to prove the charged offences beyond reasonable doubt and that the trial court had correctly appreciated the evidence and acquitted the accused.

The appeal against acquittal was therefore dismissed, the trial court’s judgment dated 20 October 2015 was confirmed, the bail bonds were cancelled, and the record and proceedings were directed to be returned to the trial court.