Murder Case Acquittal: Supreme Court Upholds High Court’s Decision

The case of State of Karnataka vs. A.B. Mahesha and Others involved an appeal by the State challenging the acquittal of the accused in a murder case. The prosecution relied on circumstantial evidence, including the last seen theory, recovery of stolen material objects, and possession of the deceased’s car by the accused.

Background of the Case

The case stemmed from the disappearance of the deceased, Jagdeesha, who was last seen alive in the company of the accused. His decomposed body was later found near a bridge on NH-48 in Kirisave Village, Karnataka. Based on circumstantial evidence, the trial court convicted the accused under Sections 302 (murder), 201 (causing disappearance of evidence), 392 (robbery), and 397 (robbery with attempt to cause death or grievous hurt) of the Indian Penal Code (IPC), sentencing them to life imprisonment.

The accused challenged their conviction before the High Court, which examined the prosecution’s evidence and identified contradictions and inconsistencies, ultimately leading to their acquittal.

Arguments by the Appellant (State of Karnataka)

The State contended the following:

• The prosecution’s case was based on strong circumstantial evidence that demonstrated that the accused were last seen with the deceased.
• The accused were found in possession of the deceased’s car and valuables, including a gold chain, Rado watch, and a gold ring.
• The trial court’s conviction was justified based on witness testimony and material evidence.
• The High Court failed to appreciate the prosecution’s evidence correctly, leading to an unjust acquittal.

Arguments by the Respondents

The respondents (accused) argued:

• The prosecution’s last seen theory was weak and uncorroborated.
• The alleged recovery of stolen items and the deceased’s car was inconsistent with the statements made by different witnesses.
• There were major contradictions in the prosecution’s case that cast doubt on the reliability of the evidence.
• The High Court had correctly examined these contradictions and rightly acquitted the accused.

Supreme Court’s Analysis

The Supreme Court analyzed the evidence presented by both parties and reviewed the inconsistencies pointed out by the High Court. The Court observed:

• The garage owner (PW-4) claimed that two accused had left the deceased’s car for repairs, while the police officer (PW-20) stated that the car was abandoned and seized by the police, leading to conflicting accounts.
• The father of the deceased (PW-3) claimed to have identified stolen items before the date when they were allegedly recovered by the investigating officer.
• The prosecution failed to establish an unbroken chain of evidence linking the accused to the murder.
• The High Court had reasonably concluded that the prosecution failed to prove the case beyond a reasonable doubt.

Supreme Court’s Judgment

After reviewing the evidence, the Supreme Court ruled:

• “When the High Court has acquitted the accused based on inconsistencies and contradictions in the prosecution’s case, this Court cannot interfere unless there are serious and substantial errors.”
• “We do not find any such serious infirmity in the judgment of the High Court warranting interference.”
• The appeal was accordingly dismissed, and the High Court’s acquittal of the accused was upheld.

Legal Precedents Considered

The Supreme Court relied on multiple precedents in deciding the case:

• Sharad Birdhichand Sarda vs. State of Maharashtra – This case laid down principles regarding reliance on circumstantial evidence for securing a conviction.
• State of U.P. vs. Satish – Reinforced that the prosecution must establish an unbroken chain of events that inevitably leads to the guilt of the accused.
• Gambhir vs. State of Maharashtra – Emphasized that circumstantial evidence must be so strong that it excludes every hypothesis except that of the accused’s guilt.

Impact of the Judgment

The judgment serves as an important reminder that courts must scrutinize circumstantial evidence carefully before securing a conviction. The ruling has several implications:

• It reinforces that inconsistencies in prosecution evidence can lead to acquittal.
• It upholds the High Court’s role in re-evaluating evidence before overturning a trial court’s verdict.
• It ensures that circumstantial evidence alone cannot lead to conviction unless it establishes guilt beyond a reasonable doubt.

Conclusion

The Supreme Court’s decision in State of Karnataka vs. A.B. Mahesha underscores the necessity for prosecution cases to be free from inconsistencies when relying on circumstantial evidence. The ruling protects against wrongful convictions and ensures that only cases with strong and reliable evidence result in sentencing.

Petitioner Name: State of Karnataka.
Respondent Name: A.B. Mahesha and Others.
Judgment By: Justice R. Banumathi, Justice Vineet Saran.
Place Of Incident: Karnataka.
Judgment Date: 14-08-2018.

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