2024 (9) TMI 1716 - SC - Indian Laws

Reversal of acquittal judgment of the Trial Court and convicting the accused under Sections 143 147 148 120B and 302 read with 149 of the Indian Penal Code (IPC) - criminal conspiracy to murder - HELD THAT - The High Court merely summed up the depositions of the so-called eyewitnesses and baldly concluded that the presence of the eyewitnesses PWs 1 to 3 could not be doubted. Surprisingly despite the Trial Court detailing at great length the contradictions and discrepancies in their depositions the High Court observed that the Trial Court had not pointed out any major contradictions which would discredit the evidence of PWs 1 to 3 and the evidence of other witnesses. According to the High Court the evidence adduced by the prosecution outweighed the findings recorded by the Trial Court but no reasons worth the name were recorded by the High Court to support this conclusion. On the strength of these cryptic observations the High Court deemed it fit to reverse the judgment of acquittal; hold the accused guilty of the offences as charged and sentence them to imprisonment for life. Once the Trial Court found no evidence to convict the accused the burden was upon the High Court while reversing the said judgment to record clear findings in relation to each of the charges and more particularly the charge of criminal conspiracy under Section 120B IPC. However no such exercise was undertaken by the High Court. At this stage it would be relevant to refer to the general principles culled out by this Court in Chandrappa and others vs. State of Karnataka 2007 (2) TMI 704 - SUPREME COURT regarding the power of the appellate Court while dealing with an appeal against a judgment of acquittal. In Rajendra Prasad v. State of Bihar 1977 (2) TMI 142 - SUPREME COURT a 3-Judge Bench of this Court pointed out that it would be essential for the High Court in an appeal against acquittal to clearly indicate firm and weighty grounds from the record for discarding the reasons of the Trial Court in order to be able to reach a contrary conclusion of guilt of the accused. It was further observed that in an appeal against acquittal it would not be legally sufficient for the High Court to take a contrary view about the credibility of witnesses and it is absolutely imperative that the High Court convincingly finds it well-nigh impossible for the Trial Court to reject their testimony. This was identified as the quintessence of the jurisprudential aspect of criminal justice. Viewed in this light the brusque approach of the High Court in dealing with the appeal resulting in the conviction of Appellant Nos. 1 and 2 reversing the cogent and well-considered judgment of acquittal by the Trial Court giving them the benefit of doubt cannot be sustained. The conviction of Appellant Nos. 1 and 2 on all charges set aside - appeal allowed.

Summary

ISSUES PRESENTED and CONSIDERED

The core legal questions considered in this judgment include:

1. Whether the High Court was justified in reversing the acquittal judgment of the Trial Court and convicting the accused under Sections 143, 147, 148, 120B, and 302 read with 149 of the Indian Penal Code (IPC).

2. Whether the evidence presented by the prosecution was sufficient to establish the guilt of the accused beyond a reasonable doubt.

3. Whether the High Court adequately addressed the contradictions and discrepancies in the testimonies of the prosecution witnesses as noted by the Trial Court.

4. Whether the High Court adhered to the principles governing appellate interference with an acquittal judgment.

ISSUE-WISE DETAILED ANALYSIS

1. Justification for Reversing Acquittal

The High Court reversed the Trial Court's acquittal without providing substantial reasoning or addressing the specific contradictions and discrepancies identified by the Trial Court. The High Court simply summarized the depositions of the eyewitnesses and concluded that their presence could not be doubted, failing to engage with the detailed analysis of the Trial Court.

Relevant Legal Framework and Precedents:

The principles governing appellate interference with an acquittal judgment were outlined in Chandrappa and others vs. State of Karnataka, which emphasize the reluctance of an appellate court to interfere with acquittals unless there are compelling reasons. The appellate court must provide clear findings and reasons when overturning an acquittal, especially in cases involving criminal conspiracy under Section 120B IPC.

Court's Interpretation and Reasoning:

The Court noted that the High Court failed to record clear findings or reasons for reversing the acquittal, particularly concerning the charge of criminal conspiracy. The High Court's approach was deemed brusque and insufficiently detailed to justify overturning the Trial Court's judgment.

Key Evidence and Findings:

The Trial Court had identified significant contradictions in the testimonies of the prosecution witnesses, particularly concerning the timing of events and the presence of witnesses at the crime scene. The High Court did not adequately address these issues.

Application of Law to Facts:

The Court applied the principles from Chandrappa and Rajendra Prasad to conclude that the High Court's reversal of the acquittal lacked the necessary detailed analysis and reasoning, thus failing to meet the required legal standards for such a decision.

2. Sufficiency of Evidence

The Trial Court found the prosecution's evidence insufficient to establish guilt beyond a reasonable doubt, noting contradictions in witness testimonies and delayed recording of statements.

Relevant Legal Framework and Precedents:

The presumption of innocence and the need for evidence to establish guilt beyond a reasonable doubt are fundamental principles in criminal jurisprudence.

Court's Interpretation and Reasoning:

The Court highlighted that the Trial Court's findings were based on a thorough examination of evidence, including the credibility of witnesses and the timing of their statements. The High Court's failure to address these issues undermined its decision to convict the accused.

Key Evidence and Findings:

The Trial Court noted discrepancies in the timing of the incident and the recording of the Spot Mahazar, as well as the lack of independent witnesses and the delay in recording statements of key witnesses.

Application of Law to Facts:

The Court found that the High Court did not provide sufficient reasoning to overturn the Trial Court's findings on the insufficiency of evidence, particularly given the contradictions and delays noted in the prosecution's case.

3. Treatment of Contradictions and Discrepancies

The High Court failed to adequately address the contradictions and discrepancies in witness testimonies as highlighted by the Trial Court.

Relevant Legal Framework and Precedents:

The appellate court must provide clear and firm grounds for discarding the Trial Court's findings, especially when discrepancies in witness testimonies are involved.

Court's Interpretation and Reasoning:

The Court criticized the High Court for not addressing the specific contradictions in witness testimonies and for failing to provide a detailed analysis of why the Trial Court's findings were incorrect.

Key Evidence and Findings:

The Trial Court noted significant contradictions in the testimonies of PWs 1 to 3 regarding the timing of events and the presence of the accused, which the High Court did not adequately address.

Application of Law to Facts:

The Court concluded that the High Court's failure to address these contradictions and discrepancies rendered its decision to reverse the acquittal unsustainable.

SIGNIFICANT HOLDINGS

Core Principles Established:

The Court reaffirmed the principles governing appellate interference with acquittals, emphasizing the need for detailed reasoning and clear findings when overturning a Trial Court's judgment.

Final Determinations on Each Issue:

The appeal was allowed, and the conviction of Appellant Nos. 1 and 2 on all charges was set aside. The judgment of the High Court was reversed to the extent of their conviction, and their bail bonds and sureties were discharged.