Supreme Court Upholds Acquittal in Murder Case: Roopwanti vs. State of Haryana (24 February 2023)

Case Background

On December 22, 2009, the respondents allegedly attacked the deceased. The deceased was hospitalized but succumbed to his injuries the next day, December 23, 2009. Following this, an FIR was lodged on December 22, 2009, at Police Station Karnal City, registered as FIR No. 905. The respondents were charged under Sections 148, 149, 323, 324, 307, 302, and 506 of the Indian Penal Code (IPC).

After investigation, a final report was submitted, and the case was committed for trial. The respondents pleaded not guilty on May 17, 2010, and a full trial was conducted. The trial judge acquitted all the respondents on October 18, 2011, citing doubts about the prosecution’s case.

The appellant, the mother of the deceased, appealed the trial court’s decision. However, the High Court of Punjab & Haryana at Chandigarh dismissed the appeal on January 24, 2013, stating that the trial court’s judgment was based on proper appreciation of evidence and facts. Aggrieved by this, the appellant approached the Supreme Court.

Timeline

Course of Proceedings

The Trial Court acquitted the respondents, stating that the eyewitnesses did not support the prosecution’s case. The court noted inconsistencies in the appellant’s testimony compared to another witness (PW1). The Trial Court also found that the appellant’s presence at the scene was not proven and considered her an “interested witness” due to her relationship with the deceased, rendering her testimony unreliable. Additionally, the Forensic Science Laboratory report found no blood on the recovered weapons, except for a trace on one lathi that could not be linked to the deceased’s blood.

The High Court upheld the Trial Court’s decision, stating that the acquittal was based on a proper assessment of the evidence and facts, and found no error in the Trial Court’s judgment.

Legal Framework

The Supreme Court emphasized the principle that an accused person is presumed innocent until proven guilty. This presumption is strengthened when an accused is acquitted after a full trial. The prosecution bears the burden of proving guilt beyond a reasonable doubt. When an acquittal is challenged, the prosecution must overcome this fortified presumption of innocence.

The Court referred to several cases to support this principle:

• Allarakha K. Mansuri Vs. State of Gujarat [2002(1) RCR(Criminal) 748]: The Supreme Court held that in cases of reversal of acquittal, where two views are possible, the view favoring the accused should be adopted. The court stated, “The golden thread which runs through the web of administration of justice in criminal case is that if two views are possible on the evidence adduced in the case, one pointing to the guilt of the accused and the other to his innocence, the view which is favourable to the accused should be adopted.”
• Suman Chandra Vs. Central Bureau Of Investigation (Criminal Appeal No.1645 of 2021): The Supreme Court stated that to reverse an acquittal, the trial court’s order must be not only erroneous but also perverse and unreasonable. The court noted, “It is well settled law that reversal of acquittal is permissible only if the view of the Trial Court is not only erroneous but also unreasonable and perverse.”
• Mrinal Das & Others Vs. The State of Tripura [2011(9) SCC 479]: The Supreme Court held that an acquittal can only be interfered with if the judgment is “clearly unreasonable” and there are “compelling and substantial reasons” for reversing the acquittal. The court stated, “An order of acquittal is to be interfered with only when there are ‘compelling and substantial reasons’, for doing so. If the order is ‘clearly unreasonable’, it is a compelling reason for interference.”

Arguments

The appellant argued that the High Court erred in upholding the trial court’s acquittal of the accused. The appellant contended that the evidence on record was sufficient to prove the guilt of the accused and that the trial court had not properly appreciated the evidence.

The respondents, on the other hand, argued that the trial court’s acquittal was justified based on the evidence and that the High Court correctly upheld the acquittal. They emphasized the principle that the presumption of innocence is strengthened after an acquittal, and that the prosecution had failed to overcome this presumption.

Issues Framed by the Supreme Court

The primary issue before the Supreme Court was whether the High Court was justified in upholding the acquittal of the respondents by the Trial Court.

Treatment of the Issue by the Court

Authorities

The Supreme Court relied on the following authorities:

Judgment

What weighed in the mind of the Court?

The Supreme Court’s decision was heavily influenced by the principle that an acquittal strengthens the presumption of innocence. The Court emphasized that when an accused is acquitted after a full trial, the prosecution faces a more significant challenge to overturn that acquittal. The Court also noted that the trial court had carefully analyzed the evidence and that there was no perversity in its findings.

The Court’s reasoning was primarily based on legal principles and precedents. The Court did consider the factual aspects of the case, but the legal framework and the principle of presumption of innocence played a more significant role in its decision.

The Supreme Court emphasized that the trial court had carefully analyzed the evidence and that there was no perversity in its findings. The Court also noted the additional layer of protection granted to the accused in cases where they have already been acquitted. The Court stated, “In the present case, we are in agreement with the decision of the High Court. From a perusal of the judgment of the Trial Court, it can be seen that no perversity has been committed by the Trial Court while reaching its conclusion.”

The Court further stated, “All the evidence on record has been carefully perused and a detailed analysis has been carried out to come to the conclusion.”

The Court also stated, “As can be seen from the above-mentioned judgments, an additional layer of protection is granted to an accused in cases where the accused already enjoys an acquittal.”

Key Takeaways

• An acquittal by a trial court strengthens the presumption of innocence.
• Reversing an acquittal requires a higher burden of proof on the prosecution.
• Appellate courts should be slow to interfere with the findings of a trial court.
• If two views are possible, the view favoring the accused should be adopted.
• Trial court judgments should not be reversed unless they are unreasonable or perverse.

Directions

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

Development of Law

The ratio decidendi of this case is that an acquittal by a trial court strengthens the presumption of innocence, and appellate courts should be hesitant to overturn such acquittals unless there is clear evidence of perversity or unreasonableness. This judgment reinforces the existing legal principles regarding the presumption of innocence and the standard for reversing acquittals, without introducing any new legal principles. The Supreme Court upheld the existing position of law.

Conclusion

The Supreme Court dismissed the appeal and upheld the acquittal of the respondents. The Court emphasized the principle that an acquittal strengthens the presumption of innocence and that appellate courts should be slow to interfere with the findings of a trial court. This judgment underscores the importance of a fair trial and the high bar for reversing an acquittal.