Double Presumption of Innocence: Supreme Court Upholds Acquittal in Ramesh v. State of Karnataka

Summary of the Judgment

• Case Name: Ramesh & Anr. v. State of Karnataka

• Date: 18th September 2024

• Judges: Honorable Justice Sanjay Kumar and Honorable Justice Aravind Kumar

• Acts and Sections Involved:

  • Sections 143, 147, 148, 302 read with Section 149 of the Indian Penal Code (IPC)

  • Section 120B IPC (criminal conspiracy)

  • Section 161 Cr.P.C.

• Cited Judgements:

  • Chandrappa & Ors. v. State of Karnataka (2007) 4 SCC 415

  • Rajendra Prasad v. State of Bihar (1977) 2 SCC 205

  • Gayadin vs. State of M.P. (2005) 12 SCC 267

Introduction

The Supreme Court of India, in Ramesh & Anr. v. State of Karnataka, addressed a crucial aspect of criminal law: the reversal of acquittal by a High Court. The case originated from an incident in 2005, where the appellants were accused of conspiring and committing the murder of Babureddy. After their acquittal by the trial court, the High Court reversed the decision, leading to this appeal in the Supreme Court.

Background of the Case

The appellants, Ramesh and his co-accused, were implicated in a First Information Report (FIR) No. 26 of 2005, registered under multiple sections of the Indian Penal Code, including charges related to unlawful assembly, rioting, and murder. The incident involved the death of Babureddy, a real estate businessman, in Bangalore Rural District. The prosecution alleged that Ramesh, along with other accused, had conspired to murder the deceased due to a dispute over a real estate transaction.

The trial court acquitted all the accused, casting doubt on the prosecution’s narrative due to inconsistencies in witness testimonies and delays in critical investigations. However, the Karnataka High Court reversed this acquittal and convicted the appellants, holding them guilty under the abovementioned sections.

Key Issues

The primary question before the Supreme Court was whether the High Court was justified in overturning the trial court's acquittal and convicting the appellants.

1. Reversal of Acquittal: The Supreme Court stressed that reversing an acquittal requires the appellate court to provide substantial and compelling reasons. It held that when a trial court acquits an accused, a double presumption of innocence comes into play. The court must not only respect the fundamental presumption of innocence but also recognise the additional weight the acquittal judgment carries.

2. Contradictions in Witness Testimonies: The trial court had acquitted the appellants, partly due to significant discrepancies in the statements of the prosecution's key witnesses. For instance, M. Ramaiah (PW-1), the prosecution’s star witness, contradicted other witnesses on whether he was alone or accompanied by others when the deceased was transported to the hospital. Furthermore, while multiple witnesses claimed to have been present at the scene, none intervened to prevent the attack, raising doubts about their reliability.

3. Delayed Recording of Witness Statements: The Supreme Court was particularly concerned with the delay in recording witness statements. Witnesses PW-2 and PW-3, who were presented as eyewitnesses, had their statements recorded under Section 161 CrPC one month after the incident. This delay cast a shadow over the veracity of their testimony. Citing the judgment in Gayadin v. State of M.P. (2005) 12 SCC 267, the court pointed out that such delays could lead to an inference of "planted witnesses".

4. High Court's Failure to Address Critical Findings: The Supreme Court observed that the High Court failed to engage with the critical findings of the trial court. The High Court had merely summarised the evidence and concluded that the presence of eyewitnesses was not in doubt, without addressing the trial court’s detailed analysis of the inconsistencies and contradictions in their testimonies.

   The Supreme Court emphasized that in an appeal against acquittal, it is not sufficient for the appellate court to take a contrary view on witness credibility without providing firm and weighty reasons to discard the trial court's assessment. The bench cited Rajendra Prasad v. State of Bihar (1977) 2 SCC 205, which held that the appellate court must demonstrate why it is "impossible" for the trial court to have reached its conclusions.

5. Failure to Establish Conspiracy: Another significant point addressed by the Supreme Court was the failure to substantiate the charge of criminal conspiracy under Section 120B of the IPC. The High Court, while convicting the appellants, did not provide clear reasoning or evidence to establish a conspiracy among the accused. The trial court, on the other hand, had noted that the alleged motive for the murder—pertaining to a failed land transaction—was not adequately supported by documentary evidence.

Conclusion

In conclusion, the Supreme Court found that the High Court had erred in reversing the acquittal without adequately addressing the findings of the trial court. The trial court had meticulously examined the evidence, and the contradictions in witness testimonies raised sufficient doubt about the prosecution’s case. The failure to promptly record key witness statements, the inconsistencies in their testimonies, and the lack of substantial evidence to prove a conspiracy all contributed to the decision.

The Supreme Court allowed the appeal, setting aside the High Court’s conviction of the appellants and restoring their acquittal. Hon’ble Justice Sanjay Kumar, delivering the judgment, remarked,

"The High Court’s approach to dismissing the detailed and reasoned findings of the trial court was brusque and unsatisfactory."

 As a result, the bail bonds of the appellants were discharged, and they were acquitted of all charges.