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State of Rajasthan v. Madan @ Madaniya

Criminal Appeal · 2018 INSC 994Decided 25 Oct 2018
Criminal Appeal No. 1333 of 2011
Justice N.V. Ramana · Justice Mohan M. Shantanagoudar

Background

The accused was alleged to have killed a woman, Santosh, by beating her with a lathi (stick) at night, following prior enmity. The trial court convicted him of murder and house-trespass, but the Rajasthan High Court later acquitted him on appeal, giving him the benefit of the doubt due to contradictions in the prosecution's evidence. The State of Rajasthan then appealed to the Supreme Court against this acquittal.

Decision Breakdown

The Supreme Court held that in an appeal against acquittal, it would only interfere if there was "perversity" in the High Court's findings, and that an acquittal carries a reinforced presumption of innocence. Examining the record, the Court found serious contradictions among the prosecution's witnesses, including two child witnesses who gave inconsistent accounts of the victim's position during the attack, unexplained delay and inconsistency in how/when the police were informed, odd conduct of the deceased's father who did not intervene or check on his daughter for hours, and gaps between the recovery memo and forensic evidence regarding a blood-stained weapon. Finding no independent corroborating witness and the case built on "conjectures and surmises," the Court held there was no perversity in the High Court's reasoning and declined to disturb the acquittal.

Lesson Learnt

An appellate court will not overturn an acquittal merely because it might have weighed the evidence differently; it will only intervene where the acquitting court's reasoning was clearly perverse, and the presumption of innocence is strengthened, not weakened, once a person has already been acquitted once.

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

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