Madhya Pradesh High Court

Leave to appeal against acquittal denied where trial court’s findings are well-reasoned and evidence-supported.

The State Of Madhya Pradesh vs Pankaj Thakur

Madhya Pradesh High CourtJUDGMENT: May 11, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

On April 28, 2015, the complainant, Umesh Sankhpal, alleged that the respondents used caste-based slurs and physically assaulted him with wooden sticks due to previous enmity

Source reference: para. 2

Following an investigation by the Ganpati Naka Police Station, charges were filed under the IPC and the SC/ST Act

Source reference: para. 3

On June 30, 2016, the Special Judge SC/ST (Prevention of Atrocities) Act, Burhanpur, acquitted the respondents in Special Case No. 09/2015

Source reference: para. 1

The State subsequently filed this petition under Section 378(3) of the Cr.P.C. seeking leave to appeal against the acquittal, alongside an application for condonation of delay

Source reference: para. 1, 7
02

Issues

1. Whether the delay in filing the petition for leave to appeal should be condoned

Source reference: para. 1

2. Whether the State presented sufficient grounds or evidence of perversity in the Trial Court's judgment to warrant the grant of leave to appeal against the acquittal

Source reference: para. 12-13
03

Law Applied

The court applied Section 5 of the Limitation Act for the condonation of delay

Source reference: para. 1

Section 378(3) of the Code of Criminal Procedure (Cr.P.C.), which governs the grant of leave to appeal against an order of acquittal

Source reference: para. 1

The court adhered to the established principle that an appellate court should only interfere with an acquittal if the trial court’s findings are perverse, contrary to evidence, or result in a miscarriage of justice

Source reference: para. 8, 12
04

Reasoning

The High Court first condoned the delay in filing based on the reasons provided in I.A.No.3094/2017

Source reference: para. 1

Regarding the merits, the Court reviewed the State's contention that the Trial Court had failed to properly appreciate cogent and documentary evidence

Source reference: para. 8-9

However, upon a "perusal of the record" and "ocular as well as documentary evidence," the High Court found that the prosecution had failed to prove the charges beyond a reasonable doubt

Source reference: para. 11

The Court determined that the Trial Court’s judgment was "well-reasoned and speaking" and found no "substantial material" or "perversity" in the lower court’s findings that would justify re-opening the case

Source reference: para. 12-13
05

Holding

The Court allowed the application for condonation of delay

The Court held that the case was not fit for grant of leave to appeal as the prosecution failed to prove its case beyond reasonable doubt and no illegality was found in the impugned judgment

Source reference: para. 11-13

Consequently, the application seeking leave to appeal and the accompanying criminal appeal were dismissed as devoid of merit

Source reference: para. 14
Madhya Pradesh High Court

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The State Of Madhya PradeshvsPankaj Thakur

Madhya Pradesh High Court · May 11, 2026

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