Supreme Court Acquits Two Men in Karnataka Murder Case After 24 Years

The Supreme Court of India recently overturned the conviction of two individuals, Krishnappa Naika @ Kittu Naika and Fedrick Cutinha, in a long-standing murder case dating back to 1999 in Dakshina Kannada, Karnataka. The judgment set aside their life sentences, emphasizing that the High Court erred in reversing their acquittal by the trial court without proper grounds. The ruling reaffirmed the legal principle that an appellate court should not lightly interfere with a trial court’s findings unless they are perverse or unreasonable.

Background of the Case

The case revolved around a violent incident that occurred on September 11, 1999, which was also the polling day for the Lok Sabha and Assembly elections. The dispute stemmed from a longstanding property feud between two factions. The prosecution alleged that a group of assailants, including the two accused, attacked members of the opposing group, leading to the death of one individual and severe injuries to others.

An FIR was lodged at Puttur Town Police Station, Dakshina Kannada, charging eleven individuals under various sections of the Indian Penal Code (IPC), including Sections 143, 147, 148 (rioting), 307 (attempt to murder), 302 (murder), and 326 (grievous hurt) read with Section 149 (unlawful assembly). The trial court acquitted all eleven accused, citing a lack of evidence. However, the Karnataka High Court reversed the acquittal of two accused—Krishnappa Naika and Fedrick Cutinha—convicting them under Section 302 read with Section 34 IPC and sentencing them to life imprisonment.

Dissatisfied with their conviction, the two accused filed separate appeals before the Supreme Court.

Petitioner’s Arguments (Krishnappa Naika & Fedrick Cutinha)

The High Court failed to provide adequate reasoning for overturning the trial court’s acquittal.
The prosecution relied heavily on the testimony of an interested witness (PW-5) without any corroborative evidence.
The trial court had already found the witness testimonies unreliable, yet the High Court convicted the appellants solely based on the same evidence.
There was no clear evidence linking the accused to the fatal attack, and no independent witnesses supported the prosecution’s claims.
Fedrick Cutinha was only accused of assaulting another person with an iron rod, and there was no evidence of him being involved in the murder.

Respondent’s Arguments (State of Karnataka)

The prosecution presented credible eyewitness accounts identifying the two accused as active participants in the attack.
The High Court exercised its appellate jurisdiction appropriately by re-evaluating the evidence and finding the trial court’s acquittal flawed.
The presence of the accused at the crime scene and their direct involvement in the attack were sufficiently established.
The prosecution urged the Supreme Court to uphold the High Court’s ruling and maintain the conviction.

Supreme Court’s Observations

The Court reaffirmed that appellate courts should be cautious in reversing acquittals unless there is a glaring legal or factual error.
It emphasized the principle that an accused person is entitled to the presumption of innocence, which is further strengthened when a trial court grants an acquittal.
The High Court did not establish that the trial court’s findings were perverse, and there was no compelling reason to overturn the acquittal.
The testimony of a single witness (PW-5) was insufficient to convict the accused, especially when the trial court had found the overall evidence unreliable.
The Court noted that Fedrick Cutinha’s alleged role was limited to throwing chili powder and attacking another person, not committing murder.

Key Judicial Findings

The Supreme Court ruled that the High Court had erred in interfering with the trial court’s acquittal without a strong basis.
The Court reiterated that in cases of acquittal, there is a “double presumption of innocence,” making it harder for an appellate court to overturn such decisions.
The conviction of Krishnappa Naika and Fedrick Cutinha was set aside, and their acquittal was reinstated.

Final Judgment

The Supreme Court ruled in favor of the appellants:

The High Court’s conviction order was quashed.
The trial court’s acquittal was restored.
The accused were ordered to be released from custody immediately.

Implications of the Judgment

The ruling has significant implications for criminal jurisprudence:

Reaffirmation of Acquittal Principles: The judgment underscores that appellate courts must have strong reasons to overturn a trial court’s acquittal.
Protection of Rights of the Accused: The decision reinforces the principle that conviction requires clear and corroborative evidence.
Standard for Reversal of Acquittal: The ruling serves as a precedent for future cases where appellate courts must provide a clear rationale before reversing acquittals.
Judicial Restraint in Criminal Appeals: The judgment acts as a caution against undue interference by appellate courts in trial court findings.

Conclusion

The Supreme Court’s decision in Fedrick Cutinha v. State of Karnataka is a landmark ruling reinforcing the principles of criminal law, particularly the standard for reversing acquittals. By setting aside the High Court’s conviction, the Court has upheld the doctrine that an appellate court must not disturb a well-reasoned acquittal unless there is a compelling reason to do so. The ruling protects the rights of accused individuals and ensures that convictions are based on robust and corroborated evidence rather than mere suspicion or weak testimony.

Petitioner Name: Fedrick Cutinha & Krishnappa Naika.
Respondent Name: State of Karnataka.
Judgment By: Justice V. Ramasubramanian, Justice Pankaj Mithal.
Place Of Incident: Dakshina Kannada, Karnataka.
Judgment Date: 18-04-2023.

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