Roopwanti vs. State of Haryana & Ors.

Criminal Appeal · 2023 INSC 157Decided 24 Feb 2023
Criminal Appeal No. 1904 of 2014
Krishna Murari · B.V. Nagarathna · Ahsanuddin Amanullah

Background

On 22 December 2009, five men allegedly attacked a man in Karnal, Haryana; he died in hospital the next day. An FIR was registered for murder, rioting and related offences, and the accused were tried. The trial court acquitted all of them in October 2011, finding the eyewitness accounts contradictory (the deceased's mother, the appellant, gave a version very different from another witness, and her presence at the scene was not proved) and noting that the forensic report found no blood on the recovered weapons except faint traces on one lathi that could not be linked to the deceased. The Punjab and Haryana High Court dismissed the mother's appeal in January 2013, and she came to the Supreme Court.

Decision Breakdown

The Supreme Court dismissed the appeal and upheld the acquittal. It explained that once a person has been acquitted after a full trial, the presumption of innocence is strengthened, and the prosecution carries a heavier burden to have that acquittal overturned. Relying on its earlier rulings (Allarakha K. Mansuri, Suman Chandra and Mrinal Das), the Court reiterated that an acquittal can be reversed only when the trial court's view is not merely wrong but perverse or unreasonable, or where material evidence was ignored or misread; if two views are reasonably possible, the one favouring the accused must be preferred. Examining the trial court's judgment, the Court found the evidence had been carefully analysed and there was no perversity, so there was no ground to interfere with either the trial court's or the High Court's decision.

Lesson Learnt

An acquittal is not easily undone: an appellate court will not reverse it just because another view of the evidence is possible, only when the acquittal is clearly unreasonable or ignores vital evidence. Contradictory eyewitness accounts and forensic evidence that does not connect the accused to the crime will generally lead to the benefit of doubt going to the accused.

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