R.S. Nayak vs A.R. Antulay
Case Brief: R.S. Nayak vs A.R. Antulay (1984) 2 SCC 183
1. Facts
The case arose from a criminal appeal filed before the Supreme Court.
The appellant, R.S. Nayak, challenged a conviction by the lower courts.
The Supreme Court examined the scope of its power to interfere with findings of fact made by lower courts.
The question was: To what extent should appellate courts re-evaluate evidence or interfere in factual findings?
2. Legal Issues
What is the scope of interference by appellate courts in findings of fact recorded by trial courts?
Should appellate courts re-assess evidence and overturn factual conclusions?
When is interference justified and when should appellate courts defer to trial courts?
3. Supreme Court’s Holding
The Supreme Court laid down important guidelines on appellate interference:
Appellate courts should not interfere with findings of fact unless there is a glaring error or misappreciation of evidence.
If the trial court’s finding is based on proper appreciation of evidence, it must be respected.
Interference is justified only if:
The finding is perverse.
There is no evidence to support the conclusion.
The conclusion is wholly untenable.
Appellate courts should not act as retrial courts.
The court emphasized respect for the trial court’s superior vantage point in assessing witness credibility and evidence.
4. Significance
The ruling established the principle of limited interference by appellate courts in factual matters.
Helped clarify the balance between the right to appeal and judicial efficiency.
Reduced unnecessary interference, promoting finality in litigation.
Widely cited in criminal and civil appellate cases concerning evaluation of evidence.
5. Related Case Laws
K. S. Puttaswamy v. Union of India (2017) — appellate powers in constitutional context.
Babu Ram v. State of Rajasthan (1997) — perverse findings test.
Raja Ram Pal v. The Hon’ble Speaker (2007) — judicial review of facts and law.
6. Summary Table
| Aspect | Details |
|---|---|
| Case | R.S. Nayak vs A.R. Antulay (1984) |
| Court | Supreme Court of India |
| Legal Issue | Scope of appellate interference in findings of fact |
| Decision | Appellate courts should defer to trial courts unless findings are perverse or unsupported by evidence |
| Significance | Limits appellate re-evaluation of evidence; respects trial court’s role |
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