Acquittal must stand where prosecution evidence fails to establish the accused’s involvement beyond reasonable doubt.

On 13 May 2016, Guddu Shakya, Ranjit Harijan and R. Prabhakaran were travelling on motorcycle No. MP-37 NC-7397. At approximately 8:00 p.m., near Chandangoda, a dumper bearing registration No. MP-05 GA-2654 allegedly collided with the motorcycle while being driven rashly and reversed without an indicator. Guddu Shakya and Ranjit Harijan sustained injuries, and R. Prabhakaran subsequently died during treatment.

An FIR was registered at Sultanpur Police Station under Sections 279 and 337 of the IPC; Section 304-A IPC was later added. After investigation, including preparation of a spot map, recording of witness statements, medical examination, seizure and mechanical inspection of the dumper, the respondent was charge-sheeted under Sections 279, 337 (two counts) and 304-A IPC. The Judicial Magistrate First Class, Gouharganj, District Raisen, acquitted the respondent on 28 May 2018, holding that the prosecution had failed to prove the charges beyond reasonable doubt. The State thereafter sought leave to appeal under Section 378(3) CrPC.

Whether the State should be granted leave under Section 378(3) CrPC to appeal against the respondent’s acquittal for offences under Sections 279, 337 and 304-A IPC.

Whether the evidence on record established that the accident and resulting injuries and death were caused by the respondent’s rash or negligent act.

Whether the trial court’s appreciation of the evidence and acquittal of the respondent disclosed an error warranting interference by the High Court.

The Court considered Section 378(3) of the Code of Criminal Procedure, which requires leave of the High Court before the State may appeal against an acquittal. The prosecution allegations concerned Sections 279 IPC, relating to rash driving or riding on a public way; 337 IPC, relating to causing hurt by an act endangering human life or personal safety; and 304-A IPC, relating to causing death by a rash or negligent act.

The Court relied on Sunil Kumar Sambhudayal Gupta (Dr.) v. State of Maharashtra, (2010) 13 SCC 657, for the principle that where two views are reasonably possible, the view favourable to the accused must be adopted.

The High Court examined the prosecution material and the trial court’s findings while considering whether the acquittal warranted appellate interference. Although the State contended that the trial court had ignored oral and documentary evidence and had been swayed by minor contradictions and omissions, the High Court found that the prosecution had failed to produce evidence establishing that the incident occurred because of the respondent’s act.

Applying the rule that the accused is entitled to the benefit of the view favourable to him where two views are possible, the Court held that the trial court’s findings were correct and that no sufficient material existed to disturb the acquittal.

Finding no merit in the State’s application for leave to appeal under Section 378(3) CrPC, the Court dismissed Misc. Criminal Case No. 31251 of 2018. The acquittal of Baddu Yadav for offences under Sections 279, 337 (two counts) and 304-A IPC therefore stood undisturbed.