Karnataka HC Upholds Acquittal Of Driver In Fatal Head-On Crash, Finding No Error In Trial Court’s Assessment Of Witness Evidence

In brief

The question

Whether the State had established grounds to interfere with the trial court’s judgment of acquittal.

The court held

The Court answered in the negative the question whether grounds had been made out to interfere with the acquittal.

It also directed

It dismissed the State’s appeal, leaving the respondent’s acquittal in force.

01Facts

The prosecution alleged that on 7 November 2016, the respondent, driving a car on NH-75, drove rashly and negligently onto the wrong side of the road and collided with an oncoming motorcycle.

¶ 1–3

The motorcycle’s rider and pillion passenger later died; occupants of the car sustained injuries.

¶ 1–3

The respondent was charged under Sections 279, 337, 338 and 304-A of the IPC.

¶ 1–3

The trial court acquitted him, and the State appealed under Section 378(1) and (3) CrPC.

¶ 1–3

02Issues

i.Whether the State had established grounds to interfere with the trial court’s judgment of acquittal.

¶ 6–7

ii.What order should follow from the Court’s determination of that issue.

¶ 6–7

03Law Applied

The Court considered the offences charged under Sections 279, 337, 338 and 304-A of the IPC and the State’s appellate jurisdiction under Section 378 CrPC.

¶ 1–3

Relying on Constable 907 Surendra Singh v. State of Uttarakhand, (2025) 5 SCC 433; Babu SahebGouda Rudragouda v. State of Karnataka, (2024) 8 SCC 149; Chandrappa v. State of Karnataka, (2007) 4 SCC 415; and H.D. Sundara v. State of Karnataka, (2023) 9 SCC 581, the Court stated that an acquittal strengthens the presumption of innocence.

¶ 8

An appellate court may reappraise the evidence but should not reverse an acquittal where the trial court’s view is plausible; interference is warranted where the judgment is perverse or materially misreads or omits evidence, and the evidence permits only a conclusion of guilt beyond reasonable doubt.

¶ 8

Provisions in the judgment · 4 · Linked ones open on LawLens

Code of Criminal Procedure, 1973 Section 378

Indian Penal Code, 1860 Section 279 Section 337 Section 338

04Reasoning

The State relied on the testimony of PWs 1–3, medical evidence, the motor vehicle inspection report and the scene sketch to argue that the respondent’s rash and negligent driving was proved.

¶ 4

On review, however, the Court noted that PW1 was seated in a jeep, reached the scene after the accident, and had not given a statement to police.

¶ 9–12, 17–19

PWs 2 and 3 admitted that the accident site was not visible from where they were and that they went to the scene after the accident.

¶ 9–12, 17–19

PW4, an occupant of the car, did not support the prosecution on rashness or negligence.

¶ 9–12, 17–19

On the evidence as a whole, the Court found no legal or factual error in the acquittal and no basis to displace the trial court’s view.

¶ 20