An acquittal based on a reasonable view of incomplete circumstantial evidence warrants no appellate interference.

The prosecution alleged that accused No. 3, the deceased Gurappa’s wife, instigated accused No. 1, with the assistance of accused No. 2, to murder Gurappa because of their alleged relationship.

It alleged that accused Nos. 1 and 2 abducted Gurappa in a vehicle, strangled him with wire and left his body in a sugarcane field.

The Sessions Court acquitted all three accused of offences under Sections 109, 120(B), 364, 302 and 201 read with Section 34 of the IPC, finding the prosecution had not proved its case beyond reasonable doubt.

The State appealed against the acquittal under Section 378(1) and (3) of the Cr.P.C., corresponding to Section 419(1) and (3) of the BNSS.

Whether the State proved that the Trial Court’s acquittal was reached without proper appreciation of the evidence.

Whether the evidence established an unbroken chain of circumstances proving the accused’s guilt for the charged offences.

In an appeal against acquittal under Section 378 Cr.P.C. (corresponding here to Section 419 BNSS), the appellate court considers whether the Trial Court’s view was a possible one on the evidence; the presumption of innocence is reinforced by acquittal, and interference requires scrutiny on accepted legal principles.

In a case based entirely on circumstantial evidence, guilt must be established through an unbroken chain of circumstances; doubtful recoveries or seizures may undermine that chain.

The Court also treated an alleged confession made while the accused was in police custody as inadmissible under Section 26 of the Indian Evidence Act.

The Court found that the prosecution case rested on circumstantial evidence and that no witness testified to seeing the abduction or murder.

The father’s account was inconsistent as to when and how he learned of the murder, and the alleged confession attributed to accused No. 3 was inadmissible.

Other evidence was also unreliable or insufficient: a witness to the inquest had not seen the body; the alleged recovery and seizure evidence was questioned; clothes were seized before the FIR was registered; and the prosecution did not explain the delay in lodging the complaint.

In those circumstances, the Court held that the prosecution had not established the required chain of circumstances and that the Trial Court’s acquittal was a permissible view of the evidence.

It confirmed the judgment and order of acquittal dated 13 December 2024 in Sessions Case No. 6/2023.