State Rep. by Inspector of Police, T.N. v. Manikandan & Ors.

Criminal Appeal · Neutral citation not assigned (Criminal Appeal Nos. 1647-1648 of 2008)Decided 28 Apr 2015
Criminal Appeal Nos. 1647-1648 of 2008
Justice Pinaki Chandra Ghose · Justice Uday Umesh Lalit

Background

Six men were accused of murdering one Gopalakrishnan over a long-standing enmity between families, allegedly by assaulting him with an "Aruval" (a large sickle-like blade) while he was cycling with his wife. Two separate trials (because two of the accused were absconding initially) both ended in acquittal, and the Madras High Court upheld both acquittals and dismissed the complainant's criminal revisions. The State and the deceased's wife then appealed to the Supreme Court.

Decision Breakdown

The Supreme Court re-examined the evidence, particularly the testimony of the deceased's wife (PW-12) and another eyewitness (PW-13), and found serious, unexplained contradictions: inconsistent accounts of how many persons were present and who struck the blows, no recovered weapon, and no blood-stained clothing from the wife despite her claim of cradling the body. Applying the settled principle (from Chandrappa v. State of Karnataka) that an appellate court should not disturb an acquittal where two reasonable views of the evidence are possible, and that acquitted persons enjoy a reinforced presumption of innocence, the Court held the prosecution had failed to prove guilt beyond reasonable doubt and dismissed the appeals, affirming the acquittals.

Lesson Learnt

Once a trial court acquits and a High Court affirms that acquittal, the Supreme Court will not re-open the case merely because a different view of the evidence is conceivable: unexplained contradictions between witnesses only reinforce the presumption of innocence rather than undermine it.

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