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Guru Dutt Pathak v. The State of Uttar Pradesh

Criminal Appeal · 2021 INSC 285Decided 6 May 2021
Criminal Appeal No. 502 of 2015
Dr. Justice D.Y. Chandrachud · Justice M.R. Shah

Background

In 1981, the Pradhan (village head) of a village in Uttar Pradesh was killed by a group of men, allegedly over a longstanding grudge, while he was walking near a river. The trial court acquitted the accused, including Guru Dutt Pathak, but the Allahabad High Court reversed the acquittal in 2014 and convicted him based on eyewitness testimony. Pathak appealed to the Supreme Court, arguing the conviction was wrongly based on reappreciation of evidence after decades.

Decision Breakdown

The Supreme Court upheld the conviction, finding the eyewitness (PW4) to be trustworthy, consistent with the FIR, and sufficient on its own to sustain the conviction. It held that the trial court's acquittal had been "perverse", contrary to and based on a misreading of the evidence, justifying the High Court's reversal. The defence's version of events was not backed by any credible evidence despite producing three defence witnesses, and the appellant had not shown he was elsewhere at the time. The appeal was dismissed, and since his earlier interim bail had not been extended, the Court ordered him to surrender to serve his sentence.

Lesson Learnt

An acquittal by a trial court is not final or untouchable: an appellate court can reverse it and convict the accused if the acquittal is shown to be based on a flawed or incomplete reading of the evidence, especially where there is a credible, consistent eyewitness.

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

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