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Nanjundappa & Anr. vs The State of Karnataka

Criminal Appeal · 2022 INSC 576Decided 17 May 2022
Criminal Appeal No. 900 of 2017
N.V. Ramana · Krishna Murari · Hima Kohli · S. Abdul Nazeer as part of the bench

Background

A telephone department employee (Appellant No. 1) and a daily-wage worker under his supervision (Appellant No. 2) were convicted for causing the death of a man who was electrocuted while trying to separate tangled telephone, TV, and cable wires at his home. The prosecution's theory was that the appellants, while working on a telephone pole, had let a telephone wire come into contact with an 11 KV high-tension power line, sending fatal current into the victim's house. The trial court and first appellate court convicted the appellants under Section 304-A (causing death by negligence) read with Section 34 IPC, and the Karnataka High Court upheld the conviction.

Decision Breakdown

The Supreme Court found the prosecution's circumstantial-evidence case scientifically and logically implausible: if an actual 11KV current had passed through the telephone wire and into the house, it would have melted the wires, destroyed the television, and almost certainly killed or severely injured anyone who touched the line, yet three other police-quarter residents who touched their telephones in the same building suffered no serious harm, and the second appellant (allegedly exposed to the same voltage) had only minor abrasions. The Court noted there was no eyewitness and no technical expert report establishing the appellants were actually working at the relevant spot or that their conduct caused the fatal current, and relied on established principles (from Syad Akbar and S.L. Goswami) that circumstantial evidence must exclude every other reasonable hypothesis and that the burden of proving guilt never shifts to the accused. Giving the appellants the benefit of the doubt, the Court set aside the conviction and sentence and allowed the appeal.

Lesson Learnt

A criminal conviction cannot rest on speculative or scientifically implausible circumstantial evidence. The prosecution must firmly establish every link in the chain of circumstances, exclude any reasonable alternative explanation, and ideally back technical claims (like the path of an electrical current) with actual expert investigation, not assumption.

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

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