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Prahlad vs. State of Madhya Pradesh & Anr.

Criminal Appeal · 2022 INSC 753Decided 27 Jul 2022
Criminal Appeal No. 983 of 2010
B.R. Gavai together with Justice P.S. Narasimha

Background

Ramesh was fatally shot in Harda, Madhya Pradesh, in June 1991, allegedly over political enmity. Three men (Mohan, Prahlad and Jagdish) were tried for murder and conspiracy, but the Sessions Judge acquitted all three for want of proof beyond reasonable doubt. The State of Madhya Pradesh appealed, and the Madhya Pradesh High Court affirmed Jagdish's acquittal but reversed the acquittals of Mohan and Prahlad, convicting them for murder and sentencing them to life imprisonment based mainly on one eyewitness and recoveries of a motorcycle and a country-made pistol ("Katta"). Mohan and Prahlad then appealed to the Supreme Court.

Decision Breakdown

The Supreme Court found the sole eyewitness's testimony riddled with contradictions and not of "sterling quality," and held that an appellate court reversing an acquittal needed far stronger evidence than this record showed. It further found the recovery of the motorcycle was actually made at the instance of a third person (not the appellants) and that the recovery of the pistol was procedurally doubtful: made from an open, publicly accessible spot with no panchnama on record. Concluding that the High Court had exceeded the limited scope permissible when reversing an acquittal, the Court allowed the appeals, set aside the convictions, and restored the trial court's acquittal of both appellants.

Lesson Learnt

An appellate court cannot overturn a trial court's acquittal merely because another view is possible; it must show the acquittal was clearly unreasonable, and convictions built on a single uncorroborated eyewitness plus procedurally shaky recoveries will not survive scrutiny.

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

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