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Wednesday, May 8

Unless there are compelling circumstances, the order of acquittal not required to be reversed in appeal


Shivasharanappa and others vs. State of Karnataka, Criminal Appeal No. 1366 of 2007 & Jagadevappa and others vs. State of Karnataka, Criminal Appeal No. 508 of 2007, Decided on May 7, 2013



The Hon’ble Supreme Court held that:


“It is clear as day that while dealing with an appeal against acquittal, the High Court has a duty to scrutinize the evidence and sometimes it is an obligation on the part of the High Court to do so. The power is not curtailed by any of the provisions of the Code of Criminal Procedure. It is also worthy to note that while re-appreciating and reconsidering the evidence upon which the order of acquittal is based, certain other principles pertaining to other facets are to be borne in mind. The said aspects have been encapsuled in Chandrappa v. State of Karnataka  (2007) 4 SCC 415 as under: -

“(4) An appellate court, however, must bear in mind that in case of acquittal, there is double presumption in favour of the accused. Firstly, the presumption of innocence is available to him under the fundamental principle of criminal jurisprudence that every person shall be presumed to be innocent unless he is proved guilty by a competent court of law. Secondly, the accused having secured his acquittal, the presumption of his innocence is further reinforced, reaffirmed and strengthened by the trial court.

(5) If two reasonable conclusions are possible on the basis of the evidence on record, the appellate court should not disturb the finding of acquittal recorded by the trial court.”

Quite apart from the above, the High Court is required to see that unless there are substantial and compelling circumstances, the order of acquittal is not required to be reversed in appeal.”


The court noted following case laws on this respect:

Shivaji Sahebrao Bobade and another v. State of Maharashtra AIR 1973 SC 2622, wherein a three-Judge Bench has opined thus: -

“.....there are no fetters on the plenary power of the Appellate Court to review the whole evidence on which the order of acquittal is founded and, indeed, it has a duty to scrutinize the probative material de novo, informed, however, by the weighty thought that the rebuttable innocence attributed to the accused having been converted into an acquittal the homage of our jurisprudence owes to individual liberty constrains the higher court not to upset the finding without very convincing reasons and comprehensive consideration.”

Girija Prasad (dead) by LRs. v. State of M. P. (2007) 7 SCC 625

State of Goa v. Sanjay Thakran  ( 2007) 3 SCC 755


To see entire text of judgment follow the link: