Supreme Court Overturns Conviction in Murder Case: Ramesh vs. State of Karnataka (2024)

Date of the Judgment: 18 September 2024

Citation: 2024 INSC 701

Judges: Sanjay Kumar, J and Aravind Kumar, J

Can a High Court reverse a Trial Court’s acquittal in a criminal case based on a mere re-evaluation of evidence without identifying clear errors in the Trial Court’s reasoning? The Supreme Court of India recently addressed this crucial question in the case of Ramesh and another vs. State of Karnataka. This judgment clarifies the stringent standards required for an appellate court to overturn an acquittal, emphasizing the double presumption of innocence in favor of the accused. The bench comprised of Justice Sanjay Kumar and Justice Aravind Kumar, with the opinion authored by Justice Sanjay Kumar.

Case Background

The case revolves around the murder of Babureddy, who was allegedly attacked on 07.02.2005 at approximately 7:30 AM near Hullahalli Gate Bus Stand in Bangalore Rural District. The prosecution claimed that the appellants, Ramesh and Kumara, along with three other accused, conspired to murder Babureddy due to a dispute over a land sale transaction. Babureddy, a real estate businessman, had mediated the sale of land belonging to Ramesh and his brother to Narayanareddy (PW-10). An advance of ₹2,50,000 was given to Ramesh and his family. However, Ramesh later asked Babureddy to cancel the transaction, which led to an altercation where Ramesh allegedly threatened Babureddy.

On the day of the incident, the prosecution alleged that Ramesh arrived on a scooter while the other accused arrived in an autorickshaw, armed with deadly weapons. They then attacked Babureddy, who later died en route to the hospital. M. Ramaiah (PW-1), a partner of the deceased, filed a complaint at 9:30 AM on the same day, leading to the registration of FIR No. 26 of 2005.

Timeline:

Course of Proceedings

The Trial Court, after examining 25 witnesses and considering the evidence, acquitted all five accused persons of all charges on 03.05.2006. The State of Karnataka appealed this decision to the High Court of Karnataka. On 29.03.2011, the High Court reversed the Trial Court’s judgment, convicting all five accused under Sections 143, 147, 148, 120B, and 302 read with 149 of the Indian Penal Code, 1860. The accused then appealed to the Supreme Court. Initially, the appeal was dismissed due to the failure of the accused to surrender. However, upon the surrender of Ramesh, Kumara, and Praveen Alexander, the appeal was restored for them. The appeal for the other two accused was dismissed as they did not surrender. Subsequently, Praveen Alexander passed away, leading to the dismissal of his appeal. Thus, the appeal was heard only with respect to Ramesh and Kumara.

Legal Framework

The case involves several key provisions of the Indian Penal Code, 1860:

• Section 143, Indian Penal Code, 1860: Deals with the punishment for being a member of an unlawful assembly.
• Section 147, Indian Penal Code, 1860: Addresses the punishment for rioting.
• Section 148, Indian Penal Code, 1860: Covers rioting while armed with a deadly weapon.
• Section 120B, Indian Penal Code, 1860: Pertains to the punishment for criminal conspiracy.
• Section 302, Indian Penal Code, 1860: Specifies the punishment for murder.
• Section 149, Indian Penal Code, 1860: Defines the concept of common object in an unlawful assembly, making all members liable for offenses committed in furtherance of that object.

Arguments

The arguments presented by both sides are detailed below:

Prosecution’s Arguments:

• Eyewitness Testimony: The prosecution heavily relied on the testimonies of M. Ramaiah (PW-1), Munikrishnappa (PW-2), and Venkatesh (PW-3), who were present at the scene of the crime. M. Ramaiah (PW-1), the deceased’s partner, provided a detailed account of the attack, naming each accused and the weapons they used.
• Motive: The prosecution argued that the motive for the murder was the dispute over the land sale transaction, where Ramesh (Appellant No. 1) allegedly threatened the deceased after being asked to approach the buyer directly.
• Autorickshaw Driver: The prosecution presented R. Shashikumar (PW-11), an autorickshaw driver, who claimed to have transported the accused to the scene of the crime and witnessed them returning with blood-stained clothes.

Defense’s Arguments:

• Inconsistencies in Eyewitness Testimony: The defense highlighted significant contradictions in the testimonies of the prosecution’s eyewitnesses. For instance, M. Ramaiah (PW-1) stated that he, along with PW-2 and PW-3, took the deceased to the hospital, while PW-2 and PW-3 contradicted this, claiming that M. Ramaiah (PW-1) went alone.
• Delay in Recording Statements: The defense pointed out that the statements of PW-2 and PW-3 were recorded under Section 161 of the Code of Criminal Procedure, 1973, one month after the incident, raising doubts about their credibility and suggesting they could be planted witnesses.
• Lack of Independent Witnesses: The defense argued that the prosecution failed to produce any independent witnesses, relying solely on related witnesses, and that no efforts were made to seize the blood-stained clothes of these witnesses.
• Discrepancies in Time of Incident: The defense highlighted that Krishnappa (PW-4), a shopkeeper, stated that the incident occurred earlier than the time claimed by the prosecution.
• Unreliable Autorickshaw Driver: The defense questioned the credibility of R. Shashikumar (PW-11), noting the delay in his statement being recorded and the fact that he did not witness the actual attack.

Submissions Table

Issues Framed by the Supreme Court

The Supreme Court framed the following issue for consideration:

1. Whether the High Court was justified in reversing the judgment of acquittal passed by the Trial Court and convicting the accused, considering the principles governing appeals against acquittals?

Treatment of the Issue by the Court

The following table demonstrates as to how the Court decided the issues:

Authorities

The Supreme Court considered the following authorities:

Cases:

Judgment

The Supreme Court allowed the appeal, setting aside the conviction of Appellant Nos. 1 and 2, Ramesh and Kumara. The Court held that the High Court had failed to provide sufficient reasons for overturning the Trial Court’s acquittal. The Supreme Court emphasized that when reversing an acquittal, the appellate court must record clear findings regarding each charge and must convincingly demonstrate why the Trial Court’s rejection of the evidence was impossible.

How each authority was viewed by the Court:

• Gayadin vs. State of M.P. [(2005) 12 SCC 267]: The Court relied on this judgment to support the inference that the delay in recording the statements of the eyewitnesses could indicate that they were planted witnesses.
• Chandrappa and others vs. State of Karnataka [(2007) 4 SCC 415]: The Court used the principles laid down in this case to reiterate the limitations on an appellate court’s power to reverse an acquittal, emphasizing the double presumption of innocence.
• Rajendra Prasad v. State of Bihar [(1977) 2 SCC 205]: The Court cited this case to highlight that the High Court must provide firm and weighty grounds for discarding the Trial Court’s reasons, which was not done in this case.

What weighed in the mind of the Court?

The Supreme Court’s decision was primarily influenced by the following factors:

• The High Court’s failure to address the significant contradictions and discrepancies in the prosecution’s evidence.
• The delay in recording the statements of crucial eyewitnesses, which raised doubts about their credibility.
• The lack of independent witnesses and the reliance on related witnesses.
• The High Court’s failure to provide clear and weighty reasons for discarding the Trial Court’s findings.
• The double presumption of innocence in favor of the accused, which requires a higher standard for reversing an acquittal.

Fact:Law Ratio

The Supreme Court’s reasoning was heavily influenced by the factual discrepancies and inconsistencies in the prosecution’s case (70%), with legal principles and precedents playing a supporting role (30%).

The Court’s reasoning was based on the principle that when an appellate court reverses an acquittal, it must provide clear and compelling reasons for doing so, especially when the trial court’s decision was based on a careful evaluation of the evidence. The Supreme Court found that the High Court had failed to meet this standard, and therefore, the acquittal was reinstated.

The court observed that the High Court did not provide any reasons worth the name to support its conclusion to reverse the judgment of acquittal. The High Court merely summed up the depositions of the so-called eyewitnesses and concluded that their presence could not be doubted, despite the Trial Court detailing the contradictions and discrepancies in their depositions. The Supreme Court held that the High Court did not record clear findings in relation to each of the charges, particularly the charge of criminal conspiracy under Section 120B of the Indian Penal Code, 1860.

The Court highlighted that “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”. The Court also emphasized the principle that “if two reasonable conclusions are possible on the basis of the evidence on record, the appellate court should not disturb the finding of acquittal recorded by the trial court.”

The Supreme Court noted that the High Court’s approach was “brusque” and that it had reversed a “cogent and well-considered judgment of acquittal by the Trial Court giving them the benefit of doubt”. The Court held that such an approach could not be sustained.

Key Takeaways

• An appellate court must provide clear and compelling reasons when reversing a trial court’s acquittal.
• The double presumption of innocence in favor of the accused is reinforced by an acquittal, requiring a higher standard for reversal.
• Contradictions and discrepancies in witness testimonies must be thoroughly addressed by appellate courts.
• Delay in recording witness statements can raise doubts about their credibility.
• The burden of proof remains on the prosecution to establish guilt beyond a reasonable doubt.

Directions

The Supreme Court directed that the bail bonds and sureties furnished by and on behalf of Appellant Nos. 1 and 2 shall stand discharged.

Development of Law

The ratio decidendi of this case is that an appellate court, when reversing a judgment of acquittal, must provide clear, cogent, and weighty reasons for doing so. The court must address all the discrepancies and contradictions in the prosecution’s evidence and must not merely re-evaluate the evidence without identifying specific flaws in the trial court’s reasoning. This judgment reinforces the principles laid down in previous cases like Chandrappa and others vs. State of Karnataka and Rajendra Prasad v. State of Bihar, emphasizing the double presumption of innocence in favor of the accused.

Conclusion

In Ramesh and another vs. State of Karnataka, the Supreme Court overturned the High Court’s decision to convict the appellants, reinforcing the principle that an appellate court must provide substantial justification to reverse an acquittal. The judgment highlights the importance of a thorough evaluation of evidence by the trial court and the need for the appellate court to identify clear errors in the trial court’s reasoning before reversing an acquittal. This case serves as a reminder of the high standards required to overturn an acquittal in criminal cases, emphasizing the double presumption of innocence in favor of the accused.