Murder Conviction Overturned: Supreme Court Acquits Accused Due to Lack of Evidence

The Supreme Court of India, in a significant ruling in the case of Bhaskarrao & Ors. v. State of Maharashtra, examined the issue of whether the High Court was justified in reversing an acquittal and convicting multiple accused in a case of brutal murder. The case stemmed from an altercation that allegedly led to the accused forming an unlawful assembly, assaulting the victim, and ultimately killing him.

The judgment, delivered by a bench comprising N.V. Ramana and S. Abdul Nazeer, delved into the principles governing appellate interference in acquittal cases and the standard of proof in criminal law. The Supreme Court ultimately reinstated the trial court’s verdict and acquitted the accused due to a lack of conclusive evidence.

Background of the Case

The case originated from an incident on June 19, 1995, in the village of Jalka Shahapur, Maharashtra. The prosecution alleged that an argument over a minor financial dispute led to a violent altercation between the deceased, Shamrao, and one of the accused. Following this, a group of sixteen individuals allegedly stormed Shamrao’s house, dragged him out, assaulted him with weapons, and ultimately left him severely injured in a nearby field.

The deceased’s wife, Chanda (PW1), was the main eyewitness. She stated that the accused assaulted her husband with sticks, an axe, and a sword, and eventually amputated his right palm. She further testified that she followed the assailants but hid out of fear. The victim’s body was discovered the next day in a field, without his right hand.

Trial Court Findings

The trial court, after a detailed examination of evidence, acquitted the accused, holding that the prosecution had failed to establish guilt beyond a reasonable doubt. Key reasons for acquittal included:

• No independent eyewitnesses supported the prosecution’s version.
• There were inconsistencies in the testimonies of the prosecution witnesses.
• The medical evidence did not corroborate the assault claims.
• No bloodstains were found on the alleged weapons.

High Court’s Reversal

The Maharashtra government appealed the acquittal, and the High Court overturned the trial court’s decision, convicting the accused under Sections 147, 148, 452, 302, and 506 of the Indian Penal Code (IPC). The accused were sentenced to life imprisonment for murder, along with additional prison terms for other charges.

Arguments Before the Supreme Court

Appellant’s Arguments

The accused challenged the High Court’s ruling, arguing:

• The High Court failed to give due consideration to the findings of the trial court, which had examined all evidence in detail.
• The prosecution’s key witnesses, including the deceased’s wife, gave inconsistent statements.
• There was no forensic evidence linking the accused to the crime.
• The High Court did not properly apply the legal standard required for overturning an acquittal.

State’s Arguments

The prosecution maintained that:

• The trial court wrongly acquitted the accused despite clear eyewitness testimony.
• Minor discrepancies in witness statements should not override the overwhelming evidence of guilt.
• The accused had committed the crime in a brutal manner and should not be acquitted.

Supreme Court’s Observations

The Supreme Court scrutinized the High Court’s decision and found that it had overstepped its appellate authority. It reiterated the well-established principle:

“The mere fact that an appellate court can arrive at a different conclusion does not justify overturning an acquittal unless the trial court’s findings are manifestly perverse or illegal.”

Additionally, the Court cited its ruling in Tota Singh v. State of Punjab, stating:

“A High Court cannot disturb an acquittal simply because it prefers a different view. The acquittal can only be overturned if the trial court’s decision is irrational or unsupported by evidence.”

Key Findings by the Supreme Court

After reviewing the case, the Supreme Court identified multiple flaws in the High Court’s ruling:

• None of the independent witnesses corroborated the prosecution’s version.
• There were significant inconsistencies in the testimony of key prosecution witnesses, including the deceased’s wife.
• The medical evidence did not support the claim of severe physical assault.
• The alleged weapons did not contain any bloodstains linking them to the crime.
• The High Court failed to demonstrate that the trial court’s acquittal was perverse or contrary to law.

Final Judgment

The Supreme Court ruled that the prosecution had failed to prove guilt beyond a reasonable doubt. It held:

“In criminal law, an accused is entitled to the presumption of innocence, and the burden lies on the prosecution to prove its case beyond all reasonable doubt. In the present case, that burden was not discharged.”

Accordingly, the Supreme Court set aside the High Court’s ruling and restored the acquittal of the accused.

Implications of the Judgment

• This ruling reaffirms the limited scope of appellate interference in acquittals.
• It underscores the importance of independent corroboration in criminal trials.
• It highlights the role of forensic evidence in establishing guilt.
• The judgment serves as a safeguard against wrongful convictions based on inconsistent testimonies.

By reinforcing the principle that an acquittal should not be overturned lightly, this ruling strengthens due process and ensures that criminal convictions are based on concrete evidence rather than conjecture.

Petitioner Name: Bhaskarrao & Ors..
Respondent Name: State of Maharashtra.
Judgment By: Justice N.V. Ramana, Justice S. Abdul Nazeer.
Place Of Incident: Maharashtra.
Judgment Date: 26-04-2018.

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