Supreme Court Upholds Acquittal in Murder Case: Roopwanti vs. State of Haryana (2023)

Date of the Judgment: 24th February 2023. Citation: 2023 INSC 157. Judges: Hon’ble Justices Krishna Murari and B.V. Nagarathna. Can an acquittal by a trial court be easily overturned by a higher court? The Supreme Court of India recently addressed this critical question in a criminal appeal, emphasizing the high threshold required to reverse an acquittal. This judgment highlights the importance of the presumption of innocence and the need for compelling reasons to overturn a lower court’s decision. The judgment was delivered by a division bench of Hon’ble Justices Krishna Murari and B.V. Nagarathna.

Case Background

On December 22, 2009, the respondents allegedly attacked the deceased. The deceased was admitted to a hospital but succumbed to his injuries the following day, December 23, 2009. The appellant, the mother of the deceased, filed a First Information Report (FIR No. 905) on December 22, 2009, at Police Station Karnal City, against the respondents under Sections 148, 149, 323, 324, 307, 302, and 506 of the Indian Penal Code (IPC). The police initiated an investigation.

Following the investigation, a final report was submitted to the court, and the case was committed for trial. The respondents were formally charged on May 17, 2010, and they pleaded not guilty. After evaluating the evidence, the trial court acquitted all the respondents on October 18, 2011, citing doubts in the prosecution’s case.

The appellant, aggrieved by the trial court’s decision, filed a criminal appeal. The High Court of Punjab & Haryana at Chandigarh dismissed the appeal on January 24, 2013, affirming that the trial court’s acquittal was based on a proper assessment of evidence and facts. The appellant then filed the present appeal before the Supreme Court.

Timeline

Course of Proceedings

The Trial Court, after examining the evidence, found the prosecution’s case doubtful and acquitted all the accused on October 18, 2011. The High Court of Punjab & Haryana dismissed the appeal on January 24, 2013, stating that the Trial Court’s judgment was based on proper appreciation of evidence and facts. The High Court found no error in the Trial Court’s decision.

Legal Framework

The case involves Sections 148, 149, 323, 324, 307, 302, and 506 of the Indian Penal Code (IPC). These sections pertain to rioting, unlawful assembly, voluntarily causing hurt, voluntarily causing hurt by dangerous weapons or means, attempt to murder, murder, and criminal intimidation, respectively. The Supreme Court also discussed the principles governing the reversal of acquittals in criminal appeals.

Arguments

The judgment does not explicitly detail the arguments of the parties. However, the following points can be inferred:

• The Appellant argued that the High Court erred in upholding the Trial Court’s acquittal.
• The Appellant’s argument was based on the premise that the evidence on record was sufficient to convict the accused.
• The Respondents argued that the Trial Court’s acquittal was correct and based on a proper appreciation of evidence.
• The Respondents also relied on the principle that an acquittal strengthens the presumption of innocence.

Issues Framed by the Supreme Court

The Supreme Court did not frame specific issues in a separate section. However, the core issue was:

1. Whether the High Court was correct in upholding the Trial Court’s acquittal, and whether there were sufficient grounds to reverse the acquittal.

Treatment of the Issue by the Court

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

Authorities

The Supreme Court relied on the following authorities:

• Allarakha K. Mansuri Vs. State of Gujarat [2002(1) RCR(Criminal) 748] – The Supreme Court cited this case to emphasize that when two views are possible, the one favoring the accused should be adopted in cases of reversal of acquittal.
• Suman Chandra Vs. Central Bureau Of Investigation [Criminal Appeal No.1645 of 2021] – This case was cited to highlight that an acquittal can only be reversed if the trial court’s view is not only erroneous but also unreasonable and perverse.
• Mrinal Das & Others Vs. The State of Tripura [2011(9) SCC 479] – The court referred to this case to reiterate that interference in a judgment of acquittal is only permissible if the judgment is clearly unreasonable and there are compelling and substantial reasons for reversing the acquittal.

Judgment

The Supreme Court dismissed the appeal, upholding the acquittal of the respondents. The Court agreed with the High Court that the Trial Court’s decision was based on a careful analysis of the evidence and did not suffer from any perversity.

How each authority was viewed by the Court?

• The Supreme Court followed Allarakha K. Mansuri Vs. State of Gujarat [2002(1) RCR(Criminal) 748]* to support its view that when two views are possible, the one favoring the accused should be adopted in cases of reversal of acquittal.
• The Supreme Court followed Suman Chandra Vs. Central Bureau Of Investigation [Criminal Appeal No.1645 of 2021]* to highlight that an acquittal can only be reversed if the trial court’s view is not only erroneous but also unreasonable and perverse.
• The Supreme Court followed Mrinal Das & Others Vs. The State of Tripura [2011(9) SCC 479]* to reiterate that interference in a judgment of acquittal is only permissible if the judgment is clearly unreasonable and there are compelling and substantial reasons for reversing the acquittal.

What weighed in the mind of the Court?

The Supreme Court’s decision was primarily influenced by the principle that an acquittal strengthens the presumption of innocence. The Court emphasized that when a trial court acquits an accused after a full trial, the presumption of innocence is fortified. To reverse such an acquittal, an appellate court must find the trial court’s decision not only erroneous but also unreasonable and perverse. The Court’s analysis shows a strong inclination towards upholding the decisions of lower courts when they have thoroughly examined the evidence and reached a reasonable conclusion. The court also noted that the trial court had carefully perused all the evidence on record and carried out a detailed analysis before reaching its conclusion.

Key Takeaways

• An acquittal by a trial court strengthens the presumption of innocence in favor of the accused.
• Appellate courts should be slow to reverse an acquittal unless the trial court’s decision is clearly unreasonable or perverse.
• When two views are possible, the one favoring the accused should be adopted.
• The prosecution bears a more onerous responsibility to reverse an acquittal.

Directions

No specific directions were given by the Supreme Court in this judgment.

Development of Law

The ratio decidendi of this case is that appellate courts should be extremely cautious when considering reversing an acquittal. The judgment reinforces the principle that an acquittal strengthens the presumption of innocence, and that there must be compelling and substantial reasons to overturn a lower court’s decision. This case does not introduce a new position of law but reaffirms the existing legal principles regarding the standards for reversing acquittals in criminal appeals.

Conclusion

The Supreme Court dismissed the appeal, upholding the acquittal of the respondents. The Court reaffirmed that an acquittal by a trial court strengthens the presumption of innocence and that appellate courts should be hesitant to reverse such decisions unless there are clear and compelling reasons to do so. The judgment emphasizes the importance of a thorough analysis of evidence by trial courts and the need for appellate courts to respect these findings unless they are clearly unreasonable or perverse.

Category

Parent Category: Criminal Law

Child Categories: Acquittal, Criminal Appeal, Presumption of Innocence, Indian Penal Code, 1860

Parent Category: Indian Penal Code, 1860

Child Categories: Section 148, Indian Penal Code, 1860, Section 149, Indian Penal Code, 1860, Section 323, Indian Penal Code, 1860, Section 324, Indian Penal Code, 1860, Section 307, Indian Penal Code, 1860, Section 302, Indian Penal Code, 1860, Section 506, Indian Penal Code, 1860

FAQ

Q: What does it mean when a court acquits someone?

A: An acquittal means that the court has found the accused not guilty of the charges brought against them. This signifies that the prosecution failed to prove the guilt of the accused beyond a reasonable doubt.

Q: What does the presumption of innocence mean?

A: The presumption of innocence means that every person is considered innocent until proven guilty. This is a fundamental principle of criminal law, and it places the burden of proof on the prosecution to prove the guilt of the accused.

Q: What happens when a higher court reviews a lower court’s acquittal?

A: When a higher court reviews a lower court’s acquittal, it must be very cautious about reversing the decision. The higher court will only overturn the acquittal if it finds that the lower court’s decision was clearly unreasonable or perverse. The presumption of innocence is strengthened when a person has been acquitted, so the higher court must have compelling reasons to reverse the acquittal.

Q: What is the significance of this judgment?

A: This judgment reinforces the legal principle that appellate courts should be slow to reverse acquittals. It highlights the importance of the presumption of innocence and the need for compelling reasons to overturn a lower court’s decision. This ensures that the decisions of trial courts are respected and that individuals who have been acquitted are not easily subjected to further legal proceedings.