Sanjay Kumar v. The State of Bihar
Background
In a 1998 incident, the appellant's father was allegedly shot dead by a group of assailants, one of whom (the respondent) was tried separately after the case against him was split off from the others. Both the trial court and, later, the Patna High Court acquitted this respondent, pointing to a mismatch between the FIR (which alleged four gunshot wounds) and the post-mortem report (which showed only three entry wounds), the fact that two independent witnesses turned hostile, and that the remaining witnesses supporting the prosecution were all relatives of the deceased. The son, as the original informant, appealed the acquittal to the Supreme Court.
Decision Breakdown
The Supreme Court dismissed the appeal, reaffirming that in cases of a concurrent acquittal by both a trial court and a High Court, it will only interfere under Article 136 where there is clear perversity or a gross misreading of evidence, not merely because a different view of the same facts is also possible. It found the inconsistencies flagged by the lower courts to be genuine and material: the mismatch between the number of alleged gunshots and the wounds actually found, the hostility of the only independent witnesses, and the fact that surviving prosecution witnesses were all interested relatives. On this basis, the benefit of the doubt was rightly extended to the accused, and the acquittal was affirmed.
Lesson Learnt
The Supreme Court is highly reluctant to overturn an acquittal that has already been upheld twice (by a trial court and a High Court); real discrepancies between medical evidence and eyewitness accounts, combined with hostile or overly interested witnesses, can validly sustain a reasonable doubt in favour of an accused person.