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K. Ravichandra & Ors. v. State of Karnataka

Criminal Appeal · 2018 INSC 793Decided 6 Sept 2018
Criminal Appeal No. 176 of 2009
Justice R. Banumathi · Justice Indira Banerjee

Background

Accused No. 1 had sent a Deepavali greeting to a young woman expressing romantic interest; when her father and another man confronted him about it near a village canteen, the appellants attacked the complainant's party with clubs. One of the men in the complainant's group, Ramu, died from his injuries. The trial court had acquitted all the accused, citing unexplained injuries on the accused themselves, inconsistent witness testimony, and a failure to prove motive or intent. The High Court reversed the acquittal and convicted the appellants under Section 304(II) IPC (culpable homicide not amounting to murder) read with Section 149 IPC, sentencing them to three years' imprisonment.

Decision Breakdown

The Supreme Court dismissed the appeal and upheld the conviction. It found the testimony of the injured eyewitnesses consistent and corroborated by medical evidence on who assaulted whom, with what weapon, and where the injuries were inflicted. The Court clarified that the prosecution is only obligated to explain injuries on the accused if those injuries are grievous in nature: here there was no such evidence, so the absence of an explanation was not fatal. It held the trial court's acquittal was based on a perverse appreciation of evidence and that the High Court had, if anything, already shown leniency in sentencing.

Lesson Learnt

An acquittal is not final or untouchable if the trial court's reasoning is found to be perverse; appellate courts can and will reverse acquittals where the evidence, read as a whole, clearly supports guilt, and the duty to "explain" injuries on the accused only arises where those injuries are serious.

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

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