Appellate interference with acquittal is unwarranted where material contradictions leave reasonable doubt.

The State of Gujarat preferred an appeal under Section 378(1) and (3) of the Code of Criminal Procedure, 1973, challenging the judgment dated 16 June 2012 by which the Trial Court acquitted the respondents in Special Atrocity Sessions Case No. 32 of 2010.

The prosecution alleged that, following a dispute concerning payment of labour charges, the accused formed an unlawful assembly, came to the complainant’s residence, abused the complainant’s husband using caste-related insults, and assaulted him with a wooden stick, bicycle chain, fists and kicks.

The complainant and her father-in-law allegedly sustained injuries when they intervened.

The accused were charged under Sections 325, 323, 324, 504 and 114 of the IPC, Sections 135 and 142 of the Bombay Police Act, and Section 3(1)(x) of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989.

The prosecution examined twelve witnesses and produced nine documentary exhibits.

The Trial Court acquitted the accused after finding material contradictions and omissions in the evidence.

In appeal, the State contended that the evidence had been improperly appreciated, whereas the respondents relied on the presumption of innocence and the settled restraint applicable to appeals against acquittal.

1. Whether the Trial Court committed an error of fact or law in acquitting the respondents-accused?

2. Whether the Trial Court improperly appreciated the oral and documentary evidence led by the prosecution?

3. Whether the judgment of acquittal was illegal, perverse, or otherwise warranted appellate interference?

4. Whether the prosecution proved the essential ingredients of the offences under the IPC, the Bombay Police Act and Section 3(1)(x) of the Atrocities Act beyond reasonable doubt?

The Court applied Sections 325, 323, 324, 504 and 114 of the IPC, Sections 135 and 142 of the Bombay Police Act, and Section 3(1)(x) of the Atrocities Act, requiring the prosecution to prove every essential ingredient of the alleged offences beyond reasonable doubt.

In considering the Atrocities Act charge, the Court relied on Shajan Skaria v. State of Kerala, 2024 AIR SC 4557, holding that caste-based insult is not established merely because the victim belongs to a Scheduled Caste or Scheduled Tribe; the insult must be connected with the victim’s caste identity and intended to cause caste-based humiliation.

The Court also referred to Sohanvir @ Sohanvir Dhama v. State of U.P., 2025 (4) Crimes 375, and related decisions concerning the requirement that caste-based abuse occur in a place within public view.

On appellate review, the Court applied the principles in Chandrappa v. State of Karnataka, (2007) 4 SCC 415, reaffirmed in 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: an appellate court may fully reappreciate evidence in an appeal against acquittal, but the acquittal strengthens the presumption of innocence, and interference is unwarranted where two reasonable views are possible.

The Court further held that an unproved medical certificate, without examining the issuing or treating doctor, could not by itself establish the nature, cause or attribution of the injuries.

The Court found that the testimonies of the complainant, her husband and her father-in-law contained material inconsistencies and exaggerations.

Although the witnesses stated in examination-in-chief that the dispute arose from unpaid labour charges, they admitted in cross-examination that no such amount was due and that the husband had instead sought a contribution towards construction of an RCC road.

The Investigating Officer also proved that several facts introduced in court had not been stated in the FIR or disclosed during investigation.

The prosecution failed to examine the doctor from S.S.G. Hospital, and therefore the medical certificates were not duly proved and could not reliably connect the alleged injuries to the respondents.

The alleged externment of respondent No.1 was also unsupported by documentary evidence.

Further, the material witness Maltiben was not examined, despite the prosecution asserting that the dispute originated from her failure to pay the alleged dues.

The record also disclosed a prior complaint by Maltiben against the complainant’s husband and others, creating an additional circumstance requiring caution.

In relation to the Atrocities Act charge, the Court held that the prosecution had not established the statutory ingredients, including caste-related intent and the legally requisite setting for the alleged abuse.

Given these evidentiary deficiencies, the Trial Court’s view was reasonable and not perverse; the enhanced presumption of innocence consequently barred appellate substitution of a merely possible contrary view.

It held that the prosecution failed to prove the alleged offences beyond reasonable doubt and that the Trial Court had neither misappreciated the evidence nor committed any illegality or perversity in acquitting the respondents.

The appeal was accordingly dismissed, the Trial Court’s judgment of acquittal was confirmed, the bail bonds were cancelled, and the record and proceedings were directed to be returned to the Trial Court.