Chandrasekhar Patel vs. Suresh & Ors.

Not available · 2023 INSC 1083Decided 30 Nov 2023
Not available
Abhay S. Oka · Pankaj Mithal

Background

In a 1996 incident, five persons were accused of murdering one Siddhnath Patel. The trial court's outcome was appealed, and the High Court ultimately acquitted the accused. Two appeals were filed against that acquittal before the Supreme Court: one by the deceased's son (an eyewitness in the case) and one by the State of Madhya Pradesh.

Decision Breakdown

The Supreme Court reiterated the settled principle that when reviewing an acquittal, an appellate court cannot reverse it merely because a different (guilty) view of the evidence is also possible. It may interfere only if the acquittal view was not one a court could reasonably have reached on the evidence, since an acquittal further strengthens the presumption of innocence. On independently examining the evidence, the Court found the trial court had wrongly disallowed several relevant cross-examination questions to a key witness, causing real prejudice to the accused, and that the accounts of the remaining eyewitnesses contained serious inconsistencies and unexplained gaps (such as failing to name assailants immediately, and police never recording statements of other nearby independent witnesses). Concluding that the High Court's acquittal was a plausible view of the evidence, the Supreme Court declined to interfere and dismissed both appeals.

Lesson Learnt

An acquittal enjoys a strong presumption of correctness on appeal; higher courts will only overturn it if the trial evidence could not reasonably support acquittal at all, not simply because a conviction was also a possible reading of the facts.

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