High Court’s Failure to Provide Reasons in Acquittal Appeal: Supreme Court Orders Reconsideration

The Supreme Court of India, in its judgment dated August 29, 2018, addressed a crucial issue regarding the responsibility of High Courts in granting or rejecting leave to appeal in criminal cases. The case, State of Uttar Pradesh vs. Anil Kumar @ Badka & Ors., revolved around the High Court’s summary rejection of the State’s plea without assigning any reasons. The Supreme Court found this to be an error in law and directed a fresh reconsideration.

The appeal arose when the Additional Sessions Judge, Kannauj, acquitted the accused in a case involving charges under Sections 363, 366, 376, and 120-B of the Indian Penal Code (IPC). The State of Uttar Pradesh sought leave to appeal this acquittal before the High Court, which dismissed the application without detailed reasoning. This prompted the State to approach the Supreme Court, questioning the legality of the High Court’s decision.

Petitioner’s Arguments

The counsel for the State of Uttar Pradesh argued that the High Court erred by rejecting the leave to appeal application without assigning reasons. He contended that there were discrepancies in the trial court’s judgment that warranted appellate scrutiny. The State relied on the Supreme Court’s ruling in State of Maharashtra vs. Sujay Mangesh Poyarekar (2008) 9 SCC 475, which emphasized the importance of applying judicial reasoning while rejecting leave to appeal.

Respondent’s Arguments

The respondents, on the other hand, contended that the High Court’s ruling was justified as the trial court’s acquittal was based on a possible view of the evidence. They argued that there was no reason to interfere with the trial court’s judgment, as another view was not necessarily warranted unless the findings were perverse.

Supreme Court’s Ruling

The Supreme Court found merit in the State’s arguments and held:

“We are constrained to observe that the High Court grossly erred in passing the impugned order without assigning any reason. In our considered opinion, it was a clear case of total non-application of mind to the case by the learned Judges because the order impugned neither sets out the facts nor the submissions of the parties nor the findings and nor the reasons as to why the leave to file appeal is declined to the appellant.”

The Court emphasized that while High Courts have discretion in granting or rejecting leave to appeal under Section 378(3) of the Code of Criminal Procedure (CrPC), they must record proper reasons while doing so. The mere assertion that the trial court’s judgment was reasonable is insufficient.

Final Verdict

Setting aside the High Court’s decision, the Supreme Court remanded the case for reconsideration with the following directions:

• The High Court must decide the State’s application for leave to appeal afresh, considering all relevant factors.
• The order must be reasoned and must address the merits of the case, rather than summarily rejecting it.
• The Supreme Court clarified that it had not made any observations on the merits of the case and left it entirely to the High Court’s judicial discretion.

Conclusion

The ruling in State of Uttar Pradesh vs. Anil Kumar @ Badka & Ors. underscores the importance of judicial reasoning in appellate matters. The Supreme Court reaffirmed that High Courts cannot reject leave to appeal applications in a mechanical manner. By ensuring that lower courts provide well-reasoned judgments, the ruling strengthens the appellate review process, reinforcing judicial accountability and transparency.

Petitioner Name: State of Uttar Pradesh.
Respondent Name: Anil Kumar @ Badka & Ors..
Judgment By: Justice Abhay Manohar Sapre, Justice Uday Umesh Lalit.
Place Of Incident: Uttar Pradesh, India.
Judgment Date: 29-08-2018.

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