Mallappa vs. State of Karnataka [February 12, 2024]
The case concerned the murder of Marthandappa, allegedly motivated by his illicit relationship with the wife of one of the accused. On June 28, 1997, Marthandappa was attacked by a group of eight, including the appellants Mallappa (A3), Hanamanth (A4), and Dharamanna (A5), while traveling in a bullock cart with PW-3 and PW-4. The prosecution claimed the accused, armed with axes, knives, and clubs, inflicted fatal injuries on Marthandappa and injured PW-4. PW-3 purportedly witnessed the incident from hiding, and PW-4, the injured witness, was hospitalized a day later. The trial court acquitted the accused, doubting the credibility of the main witnesses. The State appealed, and the High Court reversed the acquittal, convicting A3, A4, and A5 for murder under Section 302 IPC.
Supreme Court’s Analysis
Presumption of Innocence and Standard for Reversal: The Supreme Court emphasized that an order of acquittal strengthens the presumption of innocence. It reiterated that a High Court can reverse an acquittal only if the trial court’s view is perverse, manifestly illegal, or grossly unjust. A mere difference of opinion is insufficient.
Appreciation of Evidence: The trial court had meticulously analyzed the evidence, raising doubts about the credibility of PW-4, given the delayed recording of his statement, his familial relationship with the deceased, and inconsistencies in his testimony. The High Court, however, disregarded these doubts, relying solely on PW-4’s status as an injured witness without addressing the trial court’s concerns.
Holistic Approach Required: The Supreme Court criticized the High Court for failing to consider contradictions regarding the timeline, nature of injuries, and the overall chain of circumstances. The Court noted that the prosecution failed to establish a complete and consistent chain of evidence supporting guilt beyond reasonable doubt.
Two-Views Theory: The Court reaffirmed that if two plausible views arise from the evidence, the view favoring acquittal must prevail. The High Court’s approach, which set aside the acquittal on a mere change of opinion, was not permissible.
Judgment
The Supreme Court allowed the appeal, set aside the High Court’s conviction, and restored the trial court’s acquittal of the appellants. It held that the High Court had not demonstrated any illegality or perversity in the trial court’s judgment and failed to holistically appreciate the evidence.
Significance
This judgment reiterates the high threshold for reversing acquittals in criminal cases, the sanctity of the presumption of innocence, and the need for appellate courts to provide cogent reasons—rooted in manifest error or perversity—before overturning acquittals.
Citation:
Mallappa & Ors. v. State of Karnataka, [2024] 2 S.C.R. 288; 2024 INSC 104, Supreme Court of India, decided on February 12, 2024.
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