When Two Views Possible, View Favouring Accused’s Innocence To Be Adopted : SC
🔎 Context
In criminal jurisprudence, courts often encounter situations where the evidence or facts admit of two possible interpretations. One interpretation may suggest guilt, while the other may support innocence. The Supreme Court of India has consistently held that in such cases, the interpretation favoring the accused's innocence should be adopted. This principle protects the fundamental right of the accused and ensures justice by avoiding wrongful convictions.
⚖️ Legal Principle
Benefit of Doubt: The accused is entitled to the benefit of doubt when the prosecution fails to establish guilt beyond a reasonable doubt.
Two Views Doctrine: If the evidence allows two reasonable conclusions, one favoring the prosecution and the other favoring the accused, the latter should be preferred.
Presumption of Innocence: The principle reflects the presumption that the accused is innocent until proven guilty beyond reasonable doubt.
🧑⚖️ Supreme Court’s Position
The Supreme Court has elaborated on this principle in multiple judgments, emphasizing that judicial caution is necessary to prevent miscarriage of justice.
📚 Key Case Laws
1. Vishnu @ Yogesh v. State of Maharashtra, (2022) 11 SCC 212
The Supreme Court held that where two views are possible from the evidence on record, the view favorable to the accused must be adopted.
Conviction cannot be based on suspicion or on a doubtful interpretation of facts.
2. Ram Lakhan Singh v. State of Bihar, AIR 1975 SC 1554
The Court stated that the benefit of doubt must go to the accused if the prosecution’s case is not free from all doubts.
Courts should not convict if there is a plausible alternative interpretation.
3. Sanjay Dutt v. State, (1994) 5 SCC 410
The Court emphasized that any ambiguity or uncertainty in the evidence must be resolved in favor of the accused.
4. K.K. Verma v. Union of India, AIR 1973 SC 1043
It was held that where two interpretations are possible, the one consistent with the innocence of the accused should be preferred.
5. State of Uttar Pradesh v. Rajesh Gautam, (2003) 5 SCC 136
The Court reiterated that the benefit of doubt arises from lack of evidence or conflicting evidence.
In case of conflict, courts must lean in favor of the accused.
🔑 Rationale
Avoiding Wrongful Convictions: This principle is a safeguard against convicting an innocent person.
Preserving Human Rights: It upholds the constitutional guarantee of a fair trial under Article 21 (Right to Life and Personal Liberty).
Ensuring Justice: It maintains the high standard of proof required in criminal cases.
📌 Summary Table
| Aspect | Explanation |
|---|---|
| Principle | Two views possible; adopt the one favoring accused’s innocence. |
| Benefit of Doubt | Accused gets benefit if prosecution’s case not conclusive. |
| Presumption of Innocence | Fundamental right protecting accused against wrongful conviction. |
| Key Cases | Vishnu @ Yogesh, Ram Lakhan Singh, Sanjay Dutt, K.K. Verma, Rajesh Gautam |
✍️ Conclusion
The Supreme Court’s principle that when two views are possible, the one favoring the accused’s innocence must be adopted, ensures fairness and justice in the criminal justice system. This doctrine reinforces the idea that it is better to let a guilty person go free than to convict an innocent person.
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