Sudden mechanical failure resulting in loss of vehicle control negates criminal liability for rash and negligent driving.

On December 2, 2015, the deceased, Chunaram, was walking with his father, Chamurra Ram Yadav (PW-1), when a tractor (Registration No. CG-18-B-8634) driven by the respondent allegedly struck him due to rash and negligent driving.

The deceased died on the spot after the tractor overturned.

Following an investigation, the respondent was charged under Section 304A of the Indian Penal Code (IPC). The Chief Judicial Magistrate, Bijapur, acquitted the respondent on April 10, 2017, citing a lack of proof of negligence and evidence of a mechanical failure.

The State of Chhattisgarh preferred this appeal against the acquittal.

1. Whether the prosecution proved beyond reasonable doubt that the accident occurred due to the rash and negligent act of the respondent.

2. Whether the acquittal by the trial court suffers from perversity or illegality warranting interference by the High Court in an appeal against acquittal.

The court applied Section 304A of the IPC regarding causing death by negligence.

The court heavily relied on Section 378(3) of the Code of Criminal Procedure (CrPC), 1973, concerning appeals against acquittal.

The court followed the principles established in Mallappa and others v. State of Karnataka (2024) 3 SCC 544, which dictate that an appellate court should not reverse an acquittal if the trial court’s view is "legally plausible," even if a contrary view is possible, unless there is a clear error of law or perversity in fact.

The High Court observed that while PW-1 (the deceased's father) supported the prosecution's claim of high speed and negligence, the testimony of the mechanical expert, Sanjay Singh (PW-10), introduced a vital contradiction.

PW-10 testified that the tractor’s steering mechanism was broken. In cross-examination, the expert admitted that if a vehicle’s steering breaks, the driver loses all control and the vehicle is likely to overturn.

The Investigating Officer (PW-8) also confirmed the tractor was found overturned at the site. The court reasoned that the prosecution failed to prove that the steering broke as a result of the accident rather than prior to it.

Since the mechanical failure presented a reasonable possibility that the driver lost control involuntarily, the respondent was entitled to the benefit of the doubt.

The High Court dismissed the State's appeal, affirming the acquittal of the respondent. The record of the trial court was ordered to be returned.