An acquittal cannot be reversed absent patent perversity or compelling grounds warranting appellate interference.

On 31 October 2004 at approximately 11:00 p.m., Kalawati Devi alleged that the accused, Mohan Yadav, entered her house, caught hold of her daughter Sheela Kumari, and attempted to drag her outside.

When Kalawati objected, the accused allegedly assaulted Sheela with a chura, causing injuries to her chest and ribs. Sheela was taken to Siwan Hospital, where she died from her injuries.

Kalawati’s fardbeyan was recorded at Sadar Hospital, Siwan, on 1 November 2004, leading to registration of Nautan P.S. Case No. 97 of 2004 under Section 302 of the Indian Penal Code.

After investigation, the police submitted a chargesheet under Section 302 IPC, and the matter proceeded to trial.

The prosecution examined seven witnesses, including the informant, relatives of the deceased, the medical officer, and the investigating officer. The accused did not adduce defence evidence.

The trial court acquitted the accused, finding material inconsistencies regarding the place where the informant and deceased were sleeping, absence of a reliable eyewitness, non-recovery of the alleged weapon, lack of forensic examination of bloodstains, and failure to establish the place and manner of occurrence beyond reasonable doubt.

The State preferred an appeal against acquittal under Section 378(1) and (3) of the Code of Criminal Procedure, 1973.

Whether the trial court’s judgment acquitting the accused under Section 302 IPC was perverse, illegal, or otherwise liable to interference in an appeal against acquittal?

Whether the prosecution had established the place, manner, and authorship of the alleged homicidal assault beyond reasonable doubt?

Whether the evidence on record disclosed a complete chain of circumstances pointing exclusively to the guilt of the accused and inconsistent with his innocence?

The Court considered the State’s appellate jurisdiction under Section 378(1) and (3) CrPC and the charge under Section 302 IPC.

In an appeal against acquittal, the appellate court has power to review and reappreciate the evidence, but the accused enjoys a double presumption of innocence, and an acquittal should not be disturbed where two reasonable views are possible, as stated in Chandrappa v. State of Karnataka, (2007) 4 SCC 415.

The Court also relied on Surajpal Singh v. State, 1951 SCC 1207, for the principle that an acquittal may be reversed only for very substantial and compelling reasons.

Referring to Babu Sahebagouda Rudragoudar v. State of Karnataka, (2024) 8 SCC 149, the Court held that interference is justified only where the acquittal is patently perverse, based on misreading or omission of material evidence, or where no two reasonable views are possible and guilt is the only permissible conclusion.

In a case resting on circumstantial evidence, the circumstances must form a complete chain pointing exclusively to the accused’s guilt and excluding his innocence; motive may assume significance in completing such a chain, although its absence is not invariably fatal where direct evidence exists, as explained in Jan Mohammad v. State of Bihar, (1953) 1 SCC 5.

The Court found that the prosecution evidence contained material contradictions regarding the place of occurrence.

Although the informant stated in her fardbeyan that she and the deceased were sleeping together inside the house, she stated in examination-in-chief that they were sleeping separately in the courtyard; PW3 also gave a contradictory account.

The alleged weapon was not recovered, despite witnesses claiming to have seen the accused fleeing with it, and the bloodstains allegedly found at the place of occurrence were not subjected to forensic or medical examination.

The medical evidence referred to additional injuries on the cheeks and hand of the accused, whereas the prosecution witnesses spoke only of injuries to the deceased’s chest and ribs, creating further doubt regarding the manner of occurrence.

The Court also noted that no independent witness had been examined and that the witnesses who testified did not actually see the assault.

Consequently, the case could, at best, be treated as one based on circumstantial evidence, but the circumstances did not constitute a complete chain pointing only to the accused’s guilt.

The prosecution also failed to establish any motive, which assumed relevance in the absence of direct evidence.

Since the trial court’s view was a reasonably possible view based on the evidence, and was neither perverse nor founded on a misreading of the record, the enhanced presumption of innocence following acquittal required the appellate court to refrain from interference.

The trial court’s acquittal was neither illegal nor perverse, and the State failed to demonstrate any compelling or substantial ground for appellate interference.

Accordingly, the appeal was dismissed at the admission stage, and any pending applications were disposed of.