Appellate courts must not disturb acquittals where two reasonable views emerge from the evidence.

On 19 March 2011 at approximately 8:00 a.m., the complainant alleged that, near the Panchayat Office at Village Khanpur, the accused questioned his presence at the office and his operation of the Panchayat water pump, abused him by referring to his caste, threatened to kill him, and chased him while carrying an axe and an iron pipe.

He further alleged that the accused inflicted kick and fist blows, causing injuries.

An FIR, C.R. No. II-3045/2011, was registered at Tharad Police Station for offences under Sections 323, 504, 506(2) and 114 of the Indian Penal Code, 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, a charge-sheet was filed and charges were framed against the accused, who pleaded not guilty.

The trial court, after recording the prosecution evidence and the accused’s statements under Section 313 of the Code of Criminal Procedure, acquitted all accused by judgment dated 5 April 2013 in Special Case No. 48 of 2010.

The original complainant preferred the present appeal against acquittal. The State did not independently challenge the acquittal.

The High Court noted that the prosecution had not produced medical evidence, the complainant had declined medical treatment, the allegations of injury and threat were not satisfactorily corroborated, and the supporting witnesses had relevant prior connections or disputes involving the complainant.

The record also indicated that an accused had submitted an RTI application concerning alleged irregularities by the complainant, which the defence relied upon as a possible reason for the FIR.

Whether the trial court was justified in acquitting the accused of the alleged offences.

Whether the trial court properly appreciated the oral and documentary evidence led by the prosecution.

Whether the impugned judgment of acquittal suffered from any illegality, irregularity, or perversity warranting appellate interference.

Whether the prosecution proved beyond reasonable doubt the essential ingredients of Sections 323, 504, 506(2) and 114 IPC, Section 135 of the Gujarat Police Act, and Section 3(1)(x) of the SC/ST Act.

The Court applied Sections 323, 504, 506(2) and 114 of the Indian Penal Code, Section 135 of the Gujarat Police Act, and Section 3(1)(x) of the SC/ST Act, requiring the prosecution to establish each statutory ingredient beyond reasonable doubt, including intentional caste-based insult in a place within public view for the atrocity offence.

The Court relied on Hitesh Verma v. State of Uttarakhand, (2020) 10 SCC 710, and other decisions, including Shajan Skaria v. State of Kerala, AIR 2024 SC 4557, for the requirements of the offence under the SC/ST Act.

On appellate review of acquittal, the Court applied Chandrappa v. State of Karnataka, (2007) 4 SCC 415; Rajesh Prasad v. State of Bihar, (2022) 3 SCC 471; Babu Sahebagouda Rudragoudar v. State of Karnataka, (2024) 8 SCC 149; and Ramesh v. State of Karnataka, (2024) 9 SCC 169.

These authorities establish that an appellate court may fully reappreciate the evidence, but an acquittal carries a strengthened or “double” presumption of innocence, and where two reasonable views are possible, the appellate court should not disturb the acquittal.

The High Court found that the prosecution evidence did not reliably establish the alleged assault, injuries, criminal intimidation, or caste-based insult.

The complainant did not obtain medical treatment and no medical evidence was produced, weakening the allegation of bodily injury under Section 323 IPC.

The allegation of threats was also not proved beyond reasonable doubt.

With respect to Section 3(1)(x) of the SC/ST Act, the prosecution failed to establish the necessary intentional caste-based insult in a place within public view and in the circumstances required by law.

The Court further accepted that the trial court had considered the inconsistencies, the background of the prosecution witnesses, their prior involvement in related complaints, and the possible retaliatory motive arising from the RTI application against the complainant.

Since the trial court’s view was a reasonable assessment of the evidence and was not perverse, illegal, or based on a material misreading of the record, the enhanced presumption in favour of the acquitted accused prevented appellate substitution of another possible view.

The appeal against acquittal was dismissed, the trial court’s judgment dated 5 April 2013 was confirmed, the bail bonds were cancelled, and the record and proceedings were directed to be returned to the trial court.