Specific evidence of rashness or negligence is mandatory for conviction under Section 304-A IPC.

On October 23, 2000, the respondent, Hiralal, was driving a truck (Registration No. CIL-5338) carrying several labourers near village Tanakhar

The vehicle overturned, resulting in the death of one Bhuwan Singh and injuries to other passengers

A report was lodged by PW-2, and the respondent was charged under Sections 337 and 304-A of the Indian Penal Code (IPC)

By a judgment dated November 7, 2014, the Judicial Magistrate First Class, Katghora, acquitted the respondent by extending the benefit of doubt

The State subsequently appealed this acquittal

1. Whether the subject accident occurred due to the rash and negligent driving of the accused/respondent

2. Whether there is sufficient evidence to interfere with the trial court's order of acquittal

The court applied Sections 337 (causing hurt by act endangering life) and 304-A (causing death by negligence) of the IPC

Regarding the scope of interference in an appeal against acquittal, the court relied on Jafarudheen and others v. State of Kerala (2022), which held that an appellate court should be slow to reverse an acquittal as it strengthens the presumption of innocence

It further applied the principles from Mallappa and Ors. v. State of Karnataka (2024), establishing that if the trial court’s view is legally plausible, the mere possibility of a contrary view does not justify reversal

The court found that while the occurrence of the accident and the respondent’s identity as the driver were established, the prosecution failed to prove "rashness" or "negligence"

Testimony from PW-2 and PW-3 revealed that the witnesses were unaware of the vehicle's actual speed

Furthermore, PW-6 and PW-7 failed to describe any specific act of negligence or rash driving by the respondent

The High Court noted that the prosecution provided no evidence regarding road conditions, mechanical defects, or the exact speed of the vehicle to substantiate the charges under Sections 337 and 304-A IPC

Consequently, the court determined that the trial court's appreciation of evidence was proper and its conclusion to extend the benefit of doubt was a plausible one

Finding no patent illegality or perversity in the trial court's decision, the Court declined to interfere with the acquittal

The acquittal appeal filed by the State was dismissed