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Ashish Jain v. Makrand Singh (with State of Madhya Pradesh v. Makrand Singh)

Criminal Appeal · 2019 INSC 47Decided 14 Jan 2019
Criminal Appeal No. 1980 of 2008
Justice N.V. Ramana · Justice Mohan M. Shantanagoudar

Background

Three people, a money-lender, his wife, and daughter, were found murdered and robbed in their home in Madhya Pradesh in January 2003. The accused, electricians who had done repair work at the house, were convicted and sentenced to death by the trial court, but a divided High Court bench (2:1) acquitted them on appeal. The complainant (victim's nephew) and the State separately appealed the acquittal to the Supreme Court.

Decision Breakdown

The Supreme Court re-examined the entire circumstantial evidence, including "last seen" witness testimony, recovery of stolen property, and forensic evidence. It found the "last seen" testimony unreliable because it was never mentioned in the original police complaint and only surfaced later, and held that the confessions leading to recovery of stolen goods were likely obtained through improper pressure, making them inadmissible. It also found the identification of recovered jewellery procedurally flawed and the account-book evidence unreliable. Applying the principle that an acquittal carries a "double presumption of innocence," the Court held the High Court's acquittal was a reasonable view based on the record and dismissed both appeals, upholding the acquittal.

Lesson Learnt

When a High Court acquits an accused, the Supreme Court will not interfere merely because another view is possible: it will only step in if the acquittal is based on a clear misreading of evidence or a serious legal error; this reflects the strong presumption of innocence the law gives an acquitted person.

Official source (sci.gov.in)View Judgment (PDF)

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