The Chhattisgarh High Court has reaffirmed the foundational principle that an acquittal carries a strong presumption of innocence, and appellate courts must not substitute their own view unless the trial court’s reasoning is legally unsustainable. This judgment underscores the necessity of rigorous evidentiary scrutiny and the dangers of relying on inconsistent testimonies unsupported by forensic or documentary evidence.
Background & Facts
The Dispute
A violent altercation occurred on 20 August 2014 in village Hathanikala over a dispute concerning irrigation water. The complainant family - Santram @ Santu Yadav, Devlal Yadav, and Suraj Yadav - alleged that seven accused persons, armed with a tangia and bamboo sticks, launched a coordinated assault, causing grievous injuries and attempting murder. The prosecution claimed the accused formed an unlawful assembly under Section 149 IPC and committed offences under Sections 307, 323, and 294 IPC.
Procedural History
- 20 August 2014: Incident occurred; FIR (Ex.P-1) registered at Police Station Mungeli.
- Investigation: Medical reports (Exs.P-21 to P-23), seizure memos (Exs.P-8 to P-18), and FSL report (Ex.P-42) collected.
- Trial Court (15 June 2016): Acquitted all accused, holding prosecution failed to prove case beyond reasonable doubt.
- Appeals Filed: Both the complainant and the State filed acquittal appeals (ACQA No. 146/2016 and ACQA No. 26/2017).
Relief Sought
The appellants sought reversal of the acquittal and conviction of the accused, arguing that the trial court erred in disregarding the testimonies of injured eyewitnesses and ignoring material evidence.
The Legal Issue
The central question was whether an appellate court may set aside an acquittal based on a re-appreciation of evidence when the trial court’s findings are plausible, even if a contrary view is possible.
Arguments Presented
For the Appellant/Petitioner
The complainant and State contended that the testimonies of PW-1 Suraj Yadav, PW-2 Santram, and PW-3 Devlal - being injured eyewitnesses - were inherently reliable and consistent. They argued that the trial court ignored the corroborative value of seizure memos and medical reports, and that the accused’s conduct in forming an unlawful assembly with weapons was sufficient to establish guilt under Section 149 IPC. Reliance was placed on the principle that injuries sustained by witnesses lend credibility to their testimony.
For the Respondent/State
The accused argued that the prosecution’s case was riddled with material contradictions: the medical evidence contradicted allegations of axe and tangia injuries; the FIR and police statements omitted key details later introduced in court; and independent witnesses denied witnessing seizure proceedings. They emphasized that the trial court correctly applied the standard of proof beyond reasonable doubt and that appellate interference was unwarranted absent perversity or illegality.
The Court's Analysis
The High Court conducted a meticulous review of the evidence, focusing on the discrepancies between testimonial and medical records. It noted that PW-2 Santram claimed to have suffered broken teeth and axe injuries, yet Dr. G.B. Singh (PW-8) found no evidence of sharp-edged weapon injuries. Radiologist Dr. R. Jeetpure (PW-7) confirmed no fractures in PW-3 Devlal’s X-ray, directly contradicting claims of multiple stick blows. These omissions were not merely minor; they were material and went to the heart of the prosecution’s narrative.
"The allegations regarding fractures, broken teeth and injuries caused by sharp-edged weapons are not corroborated by the medical evidence."
Further, the Court highlighted that the FIR and Section 161 Cr.P.C. statements did not mention the names of all accused, nor did they specify which accused wielded which weapon. The later addition of Chandrakumar’s name via an arrow in the FIR, and the omission of Dallu and Vishnu, undermined the prosecution’s claim of spontaneity and reliability. The Court also found that independent witnesses PW-4 and PW-5 denied witnessing the seizure of weapons, rendering the recoveries legally suspect.
The Court invoked Jafarudheen v. State of Kerala and Mallappa v. State of Karnataka to reaffirm that appellate courts must not reverse acquittals merely because a different view is possible. The trial court’s conclusion - that the prosecution failed to discharge its burden - was not only plausible but well-reasoned. The High Court emphasized that partial appreciation of evidence and failure to reconcile contradictions are fatal to conviction, and that the presumption of innocence is strengthened at the appellate stage.
The Verdict
The appeals were dismissed. The Court held that the trial court’s acquittal was legally sound, as the prosecution failed to prove its case beyond reasonable doubt. The inconsistencies between testimonies, medical reports, and FIRs rendered the evidence unreliable, and no perversity or illegality justified overturning the acquittal.
What This Means For Similar Cases
Medical Evidence Cannot Be Ignored
- Practitioners must cross-verify injury allegations in witness statements with MLC and radiological reports.
- Claims of sharp weapon injuries without medical corroboration are now legally untenable.
- Prosecution must ensure medical evidence aligns with the nature of injuries described in FIR and testimony.
FIR and Police Statements Are Foundational
- Material additions in court testimony not present in Section 161 statements or FIR are treated as improvements, not corrections.
- Such inconsistencies trigger reasonable doubt and may defeat prosecution even with eyewitnesses.
- Defence counsel should systematically compare all pre-trial statements with courtroom testimony.
Appellate Courts Must Respect Trial Court’s Evidentiary Discretion
- Re-appreciation of evidence alone is insufficient to reverse acquittal.
- Appellate courts must explicitly address and refute the trial court’s reasoning, not merely substitute their own.
- The doctrine of "plausible view" now serves as a robust shield against speculative reversals.
