Acquittal Upheld Where Political Rivalry and Material Medical Contradictions Create Reasonable Doubt

On June 3, 2007, the complainant, Vastabhai Dalit, alleged that the respondents (accused) assaulted him, used caste-based slurs, and set fire to his agricultural produce worth ₹1000 due to a dispute over a compromise in a previous case

The complainant was a former Sarpanch and a failed candidate for Deputy Sarpanch against one of the accused, indicating political rivalry

Two medical certificates were issued: one by PW-8 (PHC Suigam) which named the assailants but found no visible injuries, and another by PW-3 (CHC Tharad) which found injuries but did not name the assailants

The trial Court acquitted the respondents on March 28, 2008, leading the State to file this appeal

1. Whether the trial Court was justified in passing the judgment of acquittal based on the evidentiary discrepancies

2. Whether the prosecution proved the charge of mischief by fire under Section 435 IPC and offenses under the Atrocity Act beyond a reasonable doubt

3. Whether there was any manifest illegality or perversity in the trial Court's appreciation of evidence

Section 435 of the Indian Penal Code (IPC) regarding mischief by fire with intent to cause damage to agricultural produce

Section 3(1)(10) of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989 regarding intentional insult in public view

The court relied on the appellate principles established in Chandrappa v. State of Karnataka and Rajesh Prasad v. State of Bihar, which dictate that in cases of acquittal, there is a double presumption of innocence and an appellate court should not interfere unless the trial court's view is perverse or legally untenable

The Court found significant contradictions between the ocular evidence and the medical evidence. While the complainant alleged physical assault, the primary medical examination by PW-8 recorded no external injuries despite naming the accused

Conversely, the secondary certificate by PW-3 recorded injuries but lacked the names of the assailants, creating doubt regarding the origin of the injuries

Regarding Section 435 IPC, the Court noted that the complainant’s wife did not support the allegation of arson in her testimony, and the FIR lacked specific details of the property damage

Furthermore, the Court observed that the political rivalry and the complainant's loss in local elections suggested a motive for filing a false complaint to remove the accused from their administrative posts

Applying the Chandrappa doctrine, the Court reasoned that if two reasonable views exist, the one favoring the acquittal must be upheld

The High Court held that the prosecution miserably failed to prove the charges beyond a reasonable doubt due to the lack of credible evidence and the presence of political animosity. The appeal was dismissed, and the acquittal of the respondents was confirmed