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Monday, May 27

Appellate court must bear in mind the presumption of innocence in favour of the accused

State of Madhya Pradesh vs. Dal Singh & Ors, Criminal Appeal No. 2303 of 2009, Decided on May 21, 2013


The Hon’ble Supreme Court held that:

It is a settled legal proposition that in exceptional circumstances, the appellate court for compelling reasons should not hesitate to reverse a judgment of acquittal passed by the court below, if the findings so recorded by the court below are found to be perverse, i.e. if the conclusions arrived at by the court below are contrary to the evidence on record, or if the court’s entire approach with respect to dealing with the evidence is found to be patently illegal, leading to the miscarriage of justice, or if its judgment is unreasonable and is based on an erroneous understanding of the law and of the facts of the case. While doing so, the appellate court must bear in mind the presumption of innocence in favour of the accused, and also that an acquittal by the court below bolsters such presumption of innocence.’ [Para 6]

The Court noted following case laws:

Abrar v. State of U.P., AIR 2011 SC 354;

Rukia Begum v. State of Karnataka, AIR 2011 SC 1585


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