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HC can't interfere with acquittals unless Trial Court decision 'Perverse'

HC can't interfere with acquittals unless Trial Court decision 'Perverse'

In a judgment from April 2nd, the Supreme Court reiterated fundamental principles concerning appellate review in criminal proceedings, specifically focusing on the parameters guiding High Court intervention in cases of trial court acquittals. 

The directive, enunciated by a bench comprising Justices BR Gavai and Sandeep Mehta, underscores the imperative for judicial restraint when examining appeals against acquittals.

The crux of the judgment pertains to the doctrine of two views within the ambit of criminal adjudication. In instances where the trial court acquits an accused individual, the Supreme Court emphasized that the High Court ought to abstain from interference unless the trial court's decision is characterized as perverse. 

Here, 'perverse' connotes a decision bereft of logical coherence, exhibiting unreasonableness, or lacking support from the evidence adduced during trial.

Authored by Justice BR Gavai, the judgment expounds the Court's stance, maintaining that the High Court may only overturn a trial court's acquittal if it discerns the lower court's findings to be either perverse or impossible. The judgment unequivocally denounces decisions premised solely on conjecture or speculation, stressing the imperative of a scrupulous review process.

The subject case pertains to an appeal lodged by the accused challenging the High Court's reversal of the trial court's acquittal. The trial court, having meticulously scrutinized the prosecution's evidence and discerning material discrepancies therein, acquitted the defendant due to the prosecution's failure to establish guilt beyond a reasonable doubt. 

Upon perusal of the evidentiary record, the Supreme Court aligned with the trial court's rationale, accentuating the prosecution's inability to substantiate inculpatory circumstances.

In referencing the precedent set forth in Sharad Birdhichand Sarda v. State of Maharashtra, the Supreme Court underscores the indispensable requirement of a cogent evidentiary chain to incontrovertibly establish guilt. It reiterates that suspicion, regardless of its intensity, cannot supplant the necessity for proof beyond reasonable doubt. Upholding the presumption of innocence until proven guilty, the Court underscores the exigency of conclusive evidence in criminal prosecutions.

In light of the absence of manifest errors or impossibilities in the trial court's reasoning, the Supreme Court elected to reverse the High Court's decision and acquit the accused.

Case: BALLU @ BALRAM @ BALMUKUND AND ANOTHER vs. THE STATE OF MADHYA PRADESH,

CRIMINAL APPEAL NO. 1167 of 2018.

Click here to read/download judgment.

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