Chandrappa v. State of Karnataka

Facts

The accused was tried for an offence against the person and acquitted by the trial court, which found the prosecution evidence unreliable and inconsistent and held that material witnesses were not examined. The High Court reversed the acquittal and convicted him on a reappraisal of the same evidence. The accused appealed to the Supreme Court.

Issues

• What are the powers and limits of an appellate court hearing an appeal against acquittal under S378 CrPC?
• When may an appellate court interfere with and reverse an order of acquittal?

Arguments

The appellant argued the trial court's acquittal was a reasonable view on the evidence and the High Court erred in substituting its own view. The State argued the appellate court had full power to reappraise the evidence and reach its own conclusion.

Held

The Court restated the general principles: the appellate court has full power to review, reappreciate and reconsider the entire evidence on which an order of acquittal is founded. However, two cardinal presumptions operate in favour of the accused—the presumption of innocence, reinforced by the trial court's acquittal. If two reasonable views are possible on the evidence and the trial court has taken one favouring the accused, the appellate court must not disturb it merely because another view is also possible. On the facts, the trial court's view was possible and plausible, so the High Court's reversal was set aside.

Ratio decidendi

In an appeal against acquittal the appellate court may reappraise the entire evidence, but interference is justified only if the trial court's view is not merely wrong but unreasonable or perverse; where two reasonable views exist and the trial court adopted the one favouring the accused, that acquittal must be left undisturbed.

Significance

Landmark consolidation of the law on appeals against acquittal, harmonising the line from Sheo Swarup, Sanwat Singh and Ajit Savant. Routinely cited as the governing statement; principles now apply equally to Sessions Courts hearing such appeals post-2005 amendment and carry forward under S419 BNSS.

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