Two views exist. The High Court picked the wrong one. The Supreme Court just restored the acquittal.

Two Views, One Life: The Supreme Court Restores an Acquittal the High Court Shouldn’t Have Touched

When Babu Sahebagouda Rudragoudar and two others walked out of the Supreme Court on 16 April 2024, they had spent nearly fifteen years under the shadow of a life sentence. The High Court of Karnataka had reversed their acquittal in 2009, convicting them for the murder of a farmer’s son. The Supreme Court just reversed that reversal. The question at the heart of the case was not whether the three appellants were innocent. It was whether the High Court had the right to overturn a trial court’s acquittal when the evidence was, at best, a mess of contradictions.

The stakes were simple: three men’s liberty against a conviction that the trial court had found too weak to stand. The Supreme Court’s answer was a sharp reminder of a rule every appellate judge knows but sometimes forgets—when two views are possible, the one that sets a man free must stand.

What happened in Babanagar

On 19 September 2001, a farmer named Chanagouda reported that his son Malagounda had been killed near their agricultural land in village Babanagar, Bijapur district, Karnataka. Chanagouda claimed that he and four labourers had witnessed four accused persons attack Malagounda with sharp weapons. The FIR was lodged at 4 AM the next morning. Six persons were charged with murder under Section 302 read with Section 149 IPC, along with Sections 143, 147, 148, and 506(2) IPC.

The prosecution’s case seemed straightforward. But the trial court, the Fast Track Court I at Bijapur, saw cracks from the start. On 23 July 2005, it acquitted all six accused. The judge found that the eyewitness accounts were riddled with contradictions. One witness said the assailants were known to him; another said they were strangers. The number of attackers varied. The medical evidence placed the time of death much earlier than the prosecution’s timeline suggested. And the FIR itself looked suspicious—the trial court noted it appeared to be a post-investigation document, hit by Section 162 CrPC, which bars using statements made to the police during investigation as substantive evidence.

The State appealed. The High Court of Karnataka, Circuit Bench at Gulbarga, partly allowed the appeal on 14 September 2009. It reversed the acquittal of A-1, A-2, and A-3—Babu Sahebagouda Rudragoudar and two others—and convicted them under Section 302 read with Section 34 IPC, sentencing them to life imprisonment. The acquittal of A-5 and A-6 was upheld. The appeal against A-4 had abated.

The arguments: two versions of the same evidence

Before the Supreme Court, the appellants’ counsel argued that the High Court had acted as if it were a court of first instance. It had re-appreciated the evidence without first recording a finding that the trial court’s acquittal was perverse. The learned Counsel pointed to the contradictions in the eyewitness accounts, the dubious FIR, and the medical evidence that contradicted the prosecution’s story. The trial court, they said, had taken a plausible view of the evidence. That view could not be disturbed simply because the High Court disagreed.

The State, on the other hand, argued that the High Court had the power to re-appreciate evidence in an appeal against acquittal under Section 378 CrPC. The trial court, it said, had ignored the credible eyewitness testimony. The High Court had correctly found that the prosecution had proved its case beyond reasonable doubt.

What the Supreme Court actually did

Justice Mehta, writing for the two-judge Bench, did not mince words. The High Court, the Supreme Court held, had failed to follow the settled principles governing appeals against acquittal. The judgment in Rajesh Prasad v. State of Bihar & Another (2022) 3 SCC 471, which itself culled principles from Chandrappa v. State of Karnataka (2007) 4 SCC 415, was cited. The rule is clear: an appellate court has full power to re-appreciate evidence, but it must respect the double presumption of innocence that attaches to an acquittal. If two views are possible, the view favouring the accused must prevail.

The Court also relied on H.D. Sundara & Ors. v. State of Karnataka (2023) 9 SCC 581, which summarised the same principles. The High Court, the Supreme Court found, had not recorded any finding that the trial court’s acquittal was perverse or based on a misreading of the evidence. It had simply disagreed with the trial court’s assessment and substituted its own view.

The Supreme Court then examined the evidence itself. The eyewitness accounts were contradictory on material aspects. The FIR was suspected to be a post-investigation document. The medical evidence contradicted the prosecution’s timeline. The weapon recoveries were unreliable. The trial court’s acquittal, the Supreme Court held, was not perverse. It was a plausible view of the evidence. The High Court had no business disturbing it.

THE TEST: Before reversing an acquittal, the appellate court must record a clear finding that the trial court’s view was perverse—that no reasonable person could have reached that conclusion on the evidence. If two views are possible, the acquittal stands.

The doctrine that mattered: why the High Court got it wrong

The core of the Supreme Court’s reasoning is not new, but it is often forgotten in the heat of a criminal appeal. Section 378 CrPC gives the High Court the power to hear appeals against acquittal. But that power is not unlimited. The appellate court cannot act as if the trial court never existed. It must start with the presumption that the trial court’s acquittal is correct. That presumption is strengthened by the fact that the accused has been acquitted by one court. To reverse, the appellate court must find that the trial court’s view was not just different, but impossible—that no reasonable judge could have acquitted on that evidence.

In this case, the trial court had pointed to specific contradictions. One eyewitness said he saw four assailants. Another said five. One said the assailants were known to him. Another said they were strangers. The medical officer said the death had occurred much earlier than the prosecution claimed. The FIR was lodged at 4 AM, but the investigating officer had already recorded statements before the FIR was registered—a clear violation of Section 162 CrPC.

The High Court ignored all of this. It simply re-appreciated the evidence and reached a different conclusion. That, the Supreme Court held, was not enough. The High Court had to first find that the trial court’s view was perverse. It did not. The acquittal was restored.

Why this matters in practice

For advocates, this judgment is a reminder of a basic but powerful tool. When defending an acquittal in appeal, the first question to ask is not whether the evidence supports the conviction. It is whether the trial court’s view was perverse. If the trial court took a plausible view—even if the appellate court might have decided differently—the acquittal must stand.

For founders and CFOs, the principle is the same in any adversarial system. A decision that is reasonable, even if not the only possible decision, deserves deference. The law does not demand perfection. It demands that the decision-maker act within the bounds of reason. When a court acquits, it is not saying the accused is innocent. It is saying the prosecution failed to prove guilt beyond reasonable doubt. That failure is not a mistake. It is a feature of a system that values liberty over efficiency.

The Supreme Court also made an interesting observation in obiter: motive is a double-edged sword. The same prior enmity that allegedly motivated the accused to commit the crime could equally motivate the prosecution witnesses to falsely implicate them. This is not a new principle, but it is a useful one. In cases where the prosecution relies heavily on motive, the defence can argue that the motive cuts both ways.

The bottom line

The Supreme Court allowed the appeal, set aside the High Court’s judgment dated 14 September 2009, and restored the trial court’s acquittal of A-1, A-2, and A-3. The three men, who had spent years under the weight of a life sentence, were finally free.

The lesson for every practitioner is simple: when the trial court has taken a plausible view of contradictory evidence, the High Court cannot reverse it just because it disagrees. The acquittal is not a mistake to be corrected. It is a judgment to be respected.