The Chhattisgarh High Court’s dismissal of the State’s appeal against acquittal reaffirms the foundational principle that appellate courts must exercise extreme restraint when reviewing findings of fact in criminal trials. The judgment underscores that an acquittal, especially when grounded in a plausible appreciation of evidence, cannot be overturned merely because the appellate court might have reached a different conclusion.
Background & Facts
The Dispute
The prosecution alleged that the respondent, Baliya Yadav, forcibly entered the home of the prosecutrix on the night of 5 September 2015 and committed rape. The prosecutrix, who was alone in her house after her husband had left for his in-laws’ residence, claimed the accused pushed open the unlatched door and sexually assaulted her. She later reported the incident to her husband and sister-in-law, and an FIR was registered eight days after the incident.
Procedural History
- 5 September 2015: Alleged incident occurred at the prosecutrix’s residence in Birhorpath
- 13 September 2015: FIR registered at Police Station Samripath (Ex. P/1)
- Medical examination conducted: Dr. Shashikala Toppo (PW-3) found no external or internal injuries and could not confirm recent sexual intercourse (Ex. P/6)
- Trial Court (2017): Acquitted the accused under Sections 450 and 376 IPC, citing failure of prosecution to prove case beyond reasonable doubt
- 2018: State filed appeal before High Court challenging acquittal
Relief Sought
The State sought reversal of the acquittal and conviction of the accused, arguing that the trial court erred in disbelieving the prosecutrix’s testimony and ignoring corroborative evidence, including the testimony of PW-6 (sister-in-law) and the medical opinion on the accused’s sexual capability.
The Legal Issue
The central question was whether an appellate court may set aside an acquittal merely because it finds the prosecution’s version more credible, or whether it must identify a patent illegality, perversity, or error of law in the trial court’s appreciation of evidence.
Arguments Presented
For the Appellant
The State contended that the trial court committed a legal error by overemphasizing minor contradictions in the prosecutrix’s testimony and ignoring the consistent deposition of PW-6 (sister-in-law), who corroborated the occurrence of the incident. It argued that the delay in filing the FIR was explained by fear and social stigma, and that the medical report’s failure to confirm recent intercourse did not negate the allegation, as absence of injury is common in rape cases involving known persons. The State relied on the principle that the court must not require perfection in the testimony of victims of sexual violence.
For the Respondent
The respondent did not appear, but the High Court noted that the trial court’s reasoning - based on the prosecution’s failure to establish credibility due to hostile witnesses and lack of medical corroboration - was legally sound. The defense implicitly supported the trial court’s view that the prosecution’s case collapsed under its own weight.
The Court's Analysis
The High Court conducted a meticulous review of the trial court’s reasoning and the evidence on record. It emphasized that the prosecution’s case was fatally undermined by the fact that the prosecutrix (PW-1) and her husband (PW-2) both denied the allegations during trial, despite having previously made statements to the police. The court further noted that the sister-in-law (PW-4) and other witnesses also retracted their earlier statements, rendering the prosecution’s narrative unsupported.
"Our criminal jurisprudence is essentially based on the promise that no innocent shall be condemned as guilty. All the safeguards and the jurisprudential values of criminal law, are intended to prevent any failure of justice."
The Court cited Mallappa v. State of Karnataka to reaffirm that appellate courts must not substitute their own view for that of the trial court unless the latter’s finding is perverse, legally untenable, or based on a misreading of evidence. The trial court’s conclusion - that the prosecution failed to prove its case beyond reasonable doubt - was deemed a legally plausible view, given the hostile nature of key witnesses and the absence of corroborative medical evidence.
The Court rejected the State’s argument that the delay in filing the FIR was suspicious, noting that such delays are common in rural settings where victims face social pressure and fear of stigma. It also held that the medical report’s inability to confirm recent intercourse did not invalidate the allegation, but the absence of any corroborative testimony rendered the prosecution’s case inherently unreliable.
The Verdict
The State’s appeal was dismissed. The Court held that the trial court’s acquittal was neither perverse nor legally flawed, and that the appellate court cannot interfere merely because it might have reached a different conclusion. The principle of deference to trial court findings in criminal acquittals was firmly upheld.
What This Means For Similar Cases
Appellate Courts Must Not Reappreciate Evidence Arbitrarily
- Practitioners must argue that reversal of acquittal requires proof of perversity, not just a different interpretation
- Merely pointing to inconsistencies in testimony is insufficient; the trial court’s reasoning must be shown to be irrational or legally unsustainable
- The burden lies on the prosecution to establish a clear, unbroken chain of credible evidence
Hostile Witnesses Undermine Prosecution’s Case
- If key prosecution witnesses retract or deny allegations during trial, the prosecution must explain why their earlier statements were truthful
- Declaring a witness hostile does not automatically validate prior statements; the court must still assess their reliability
- In sexual offense cases, the absence of corroborative testimony cannot be compensated by emotional appeals or general assumptions
Medical Evidence Is Not Always Dispositive
- Absence of injury or forensic confirmation does not equate to absence of offense
- However, when medical evidence contradicts the prosecution’s version and no other credible evidence supports it, the case collapses
- Prosecutors must secure timely and comprehensive forensic reports and ensure chain of custody is unbroken
