Supreme Court Lays Down Guidelines for Appellate Courts on Appeals from Acquittal
In the case of MALLAPPA & ORS. VERSUS STATE OF KARNATAKA, the Supreme Court emphasized the importance of evidence appreciation in criminal trials. It highlighted that when evidence allows for two interpretations, the trial court's decision to acquit should prevail over the possibility of an alternate view leading to conviction, unless there are compelling reasons otherwise.
The bench, comprising Justices Bela M. Trivedi and Satish Chandra Sharma, emphasized that the perspective favoring the accused's innocence should be given precedence over any indication of guilt when two plausible views arise from the evidence.
Justice Satish Chandra Sharma, in authoring the judgment, laid down six key principles for Appellate Courts to consider when handling appeals from acquittals. These principles aim to ensure a fair and comprehensive review of the trial court's decision:
1. Comprehensive appreciation of evidence: All types of evidence, whether oral or documentary, must be thoroughly evaluated.
2. Risk of selective appreciation: Partial or selective evaluation of evidence may lead to a miscarriage of justice and should be challenged.
3. Preference for the accused: If two plausible views emerge from the evidence, the one favoring the accused's innocence should typically be adopted.
4. Legal tenability of trial court view: A trial court's decision should not be overturned solely because another plausible view exists unless there are compelling legal reasons.
5. Addressing trial court reasons: Any reversal of acquittal must address all the reasons provided by the trial court and cover all relevant facts.
6. Demonstrating legal flaws: Reversal of acquittal requires demonstrating illegality, perversity, or error in the trial court's decision.
Applying these principles, the court found that the High Court erred in reversing the acquittal without identifying any legal flaws in the trial court's reasoning. Consequently, the appellants were acquitted of all charges.