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Legal Case Shots

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Legal Case Shots is a searchable database of Supreme Court of India judgments, each broken down into the case type, the court's key holding, and a practical lesson learnt, with the full judgment available as a PDF for citation or deeper reading.

Criminal LawSupreme Court of India

Jai Prakash v. The State of Uttar Pradesh and Others

Criminal Appeal · 2019 INSC 1294Decided 28 Nov 2019
Criminal Appeal Nos. 1790-1791 of 2019
Justice R. Banumathi · Justice A.S. Bopanna · Justice Hrishikesh Roy

Background

The appellant's brother, Ravi Prakash, was shot dead in 1992, allegedly by three men over a pre-existing enmity linked to a newspaper report critical of one of the accused. The trial court convicted three of the four accused based on the testimony of the complainant (the victim's brother) and another eyewitness, sentencing them to life imprisonment. The Allahabad High Court later reversed this, acquitting all three accused after finding the prosecution's version riddled with inconsistencies, and both the original complainant and the State of Uttar Pradesh appealed that acquittal to the Supreme Court.

Decision Breakdown

The Supreme Court undertook its own independent re-appreciation of the evidence and agreed with the High Court's doubts about the prosecution's case: the alleged "chance" presence of the second eyewitness was unexplained and suspicious, the victim's trip to buy gutkha from a farther shop instead of a nearer one was never satisfactorily explained, there were unexplained inconsistencies between the oral testimony and the medical evidence (including an unexplained fourth gunshot wound), and crucial physical evidence such as spent cartridge cases and the murder weapons were never recovered despite prompt investigation. Applying the settled principle that an appellate court should not disturb an acquittal unless the High Court's findings are perverse or suffer from a glaring infirmity, the Supreme Court found no such infirmity and held the acquittal was properly reasoned. Both appeals (by the complainant and by the State) were dismissed and the acquittal was affirmed.

Lesson Learnt

An appellate court, including the Supreme Court, will not overturn a reasoned acquittal merely because another view of the evidence is possible: it must find the acquitting court's reasoning genuinely perverse or unsupportable, which keeps the benefit of the doubt firmly with an accused once properly acquitted.

Jai Prakash v. The State of Uttar Pradesh and Others – Legal Case Shots | LegalAware