In a recent verdict, the Supreme Court underscored the principle that if an appellate court, upon review of evidence in an appeal against acquittal, finds two plausible views, the one favoring the innocence of the accused must prevail.
The Bench, comprising Justices Bela M. Trivedi and Satish Chandra Sharma, overturned the High Court’s decision to convict the accused, which contradicted the trial court’s acquittal order. The judgment emphasized that the High Court should refrain from convicting the accused by reevaluating evidence if the trial court’s view is reasonable.
According to Justice Satish Chandra Sharma’s authored judgment, the ‘two-views theory’ acknowledges that when evidence allows for two equally plausible interpretations, the one favoring the accused must be favored. This principle not only upholds the presumption of innocence but also reinforces the need for certainty in convictions.
The case in question involved the trial court’s acquittal of the accused of murder charges under Section 302 of the Indian Penal Code. The trial court, after careful examination, deemed the testimony of Prosecution Witness No. 3 unreliable, finding inconsistencies that cast doubt on guilt.
Upon appeal by the State, the High Court reversed the acquittal, relying heavily on the injured witness, PW-3’s testimony. However, the Supreme Court noted critical omissions in the High Court’s analysis, particularly regarding the timing of PW-4’s statement and his relationship with the deceased.
The accused argued that the High Court erred by disregarding the trial court’s evaluation of evidence unless a significant error was identified. Conversely, the State contended that the trial court’s assessment was flawed, justifying the High Court’s intervention.
The Supreme Court, after considering both arguments, emphasized that while the High Court has the authority to reevaluate evidence, it must do so comprehensively. Partial appreciation of evidence, the court stressed, could lead to unjust outcomes.
The court outlined three key considerations for the High Court during such reviews: whether the trial court thoroughly considered all evidence, whether its decision was legally or factually erroneous, and whether its view was plausible. The overturning of an acquittal, the court asserted, should only occur in cases of clear illegality or perversity, not merely due to differing opinions.
In conclusion, the Supreme Court set aside the High Court’s conviction, reaffirming the importance of cautious review in appellate courts.
The legal representatives involved in the case were Mr. Basavaprabhu Patil, Ms. Supreeta Sharanagouda, Mr. Sharanagouda Patil for the appellants, and Nr. Nishanth Patil, Mr. D. L. Chidananda for the respondents.
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