Karnataka HC Upholds Acquittal Of Husband, Brother In Wife’s Alleged Murder, Citing Gaps In Circumstantial Evidence

The State appealed against the acquittal of the respondents, who had been charged under Sections 302 read with 34 of the Indian Penal Code (IPC) for the death of Laxmi, wife of accused No. 1.

The prosecution alleged that accused No. 1 strangled Laxmi with a veil while accused No. 2 kept watch. Its case was based on circumstantial evidence.

The prosecution examined 16 witnesses; the trial court found the evidence insufficient to prove guilt beyond reasonable doubt and acquitted both accused on 29 November 2025.

The State challenged that acquittal, arguing that the trial court had failed to properly assess the evidence, including that of the deceased’s family members.

The Court considered the offence charged under Sections 302 read with 34 IPC and the principles governing a State appeal against acquittal under Section 378 of the Code of Criminal Procedure (CrPC), now corresponding to Section 419 of the Bharatiya Nagarik Suraksha Sanhita (BNSS).

An appellate court may review and reappreciate the evidence, but an acquittal should not be reversed merely because another view is possible; where the trial court’s view is a reasonable and possible one, it must stand.

If the evidence reasonably supports two views, the view favourable to the accused should be adopted.

Interference is warranted where, among other things, the trial court’s conclusion is perverse or its judgment is clearly unreasonable.

The High Court found that the prosecution’s circumstantial case did not establish a complete chain pointing to the respondents’ guilt.

The alleged motive—accused No. 1’s suspicion about Laxmi’s relationship with Dastappa—was not supported by the relevant witnesses.

Although the doctor’s evidence attributed death to asphyxia caused by constriction of the neck, the Court considered the evidence insufficiently clear as to whether the death resulted from strangulation, throttling, or hanging.

The inquest and postmortem records also did not adequately describe the neck injuries, and investigating officer PW15’s evidence that he found the body hanging further left the manner of death uncertain.

The High Court therefore held that the trial court’s assessment and benefit of doubt were reasonably available on the evidence, and did not justify appellate interference.

It dismissed the appeal and confirmed the trial court’s judgment acquitting both respondents of the offence under Section 302 read with Section 34 IPC.