Appellate courts must uphold acquittals absent perversity or manifest error in the trial court’s findings.

The prosecution alleged that, on 19 July 2011, the complainant and his mother were assaulted in a public market after the complainant accidentally touched the accused.

It further alleged that the accused used caste-related abusive words, threatened them, and caused hurt.

The accused was charged under Sections 323, 504 and 506(2) of the Indian Penal Code, Section 135 of the Bombay Police Act and Section 3(1)(10) of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989.

The trial court acquitted him, and the State appealed under Section 378(1)(3) of the Code of Criminal Procedure, 1973

Whether the trial court was justified in acquitting the accused

Whether the trial court properly appreciated the prosecution evidence and whether its judgment disclosed any illegality, irregularity or perversity warranting appellate interference

The prosecution was required to prove the charged offences beyond reasonable doubt.

For an offence under Section 3(1)(10) of the Atrocities Act, the Court stated that the prosecution must establish intentional insult or intimidation, knowledge of the victim’s Scheduled Caste or Scheduled Tribe status, and commission of the act in a place within public view.

In an appeal against acquittal, the appellate court may review and reappreciate the evidence, but must account for the reinforced presumption of innocence; where two reasonable views are possible, it should not disturb the acquittal.

The Court relied on 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, on appellate review of acquittals

The Court found that the complainant’s and his mother’s alleged injuries were not corroborated by the medical evidence: the doctor observed no external or internal injuries, and the complaints of pain were subjective

No independent market witnesses were examined, the mother did not support the allegation of caste-related abuse, and the witness who arrived later gave an inconsistent incident date and did not witness the assault

The Court concluded that the evidence did not establish the assault or the essential ingredients of the Atrocities Act offence beyond reasonable doubt

Given the applicable principles governing appeals against acquittal, it found no perversity or manifest error that justified interference

The State’s appeal was dismissed, the acquittal was confirmed, the bail bond was cancelled, and the record and proceedings were ordered to be returned to the trial court.