Suppression of cross-case and injuries to accused justifies acquittal by validating right of private defence.

The State appealed against a judgment dated 22.08.2017 by the JMFC, Amarpatan, which acquitted the respondents of charges under Sections 294, 323, 324, 325, 506 Part-II, and 34 of the IPC.

The prosecution alleged that on 01.08.2013, the respondents assaulted the complainant, Shridhar Yadav (PW-1), and his family with a trident and sticks over a land cultivation dispute.

The trial court acquitted the accused, primarily finding that the prosecution failed to explain injuries sustained by the accused and suppressed the genesis of the incident, suggesting the accused may have acted in private defense of property.

1. Whether the trial court erred in granting the benefit of doubt to the accused despite the testimony of injured eye-witnesses.

2. Whether the non-explanation of injuries sustained by the accused and the suppression of a cross-case by the prosecution are fatal to the case.

3. Whether the appellate court should interfere with an order of acquittal when a plausible view has been taken by the trial court.

The court primarily applied the principle from Laxmi Singh v. State of Bihar (1976), holding that non-explanation of serious injuries on the accused suggests the prosecution has suppressed the genesis of the occurrence, rendering the case doubtful.

Regarding the scope of appellate review of acquittals under Section 378 of the CrPC, the court relied on H.D. Sundara v. State of Karnataka (2023), Babu Sahebagouda Rudragoudar v. State of Karnataka (2024), and Mallappa v. State of Karnataka (2024), which establish that an appellate court should not overturn an acquittal if the trial court’s view is a "legally plausible view," even if a contrary view is possible.

The Court observed that while PW-1, PW-2, and PW-3 supported the prosecution, they were related witnesses whose testimonies contained material contradictions and omissions.

Crucially, PW-1 admitted the accused had been cultivating the disputed land for 14 years and that the conflict arose when the complainant party attempted to stop them.

The prosecution failed to examine independent neighbors as witnesses or produce documentation proving possession.

Furthermore, the prosecution suppressed evidence of a pending cross-case and injuries sustained by the accused (Ramavatar), which PW-1 implausibly claimed were self-inflicted.

Applying Laxmi Singh, the court reasoned that this suppression indicated the prosecution did not present a true version of the incident.

Since the injuries to the victims could also have resulted from falling, the trial court's decision to favor the accused's right of private defense was deemed a possible and reasonable view.

The High Court dismissed the appeal and affirmed the acquittal.

It held that the trial court's findings were not perverse, illegal, or unreasonable.