Presumed Guilty to Proven Innocent: Supreme Court’s Bold Reversal in Mallappa Murder Case Sparks Legal Milestone
TITLE: MALLAPPA & ORS. V. STATE OF KARNATAKA
CITATION: CRIMINAL APPELLATE JURISDICTION CRIMINAL APPEAL NO. 1162 OF 2011
DECIDED ON: 12 FEBRUARY 2024
CORAM: JUSTICE BELA M. TRIVEDI, JUSTICE SATISH CHANDRA SHARMA
Facts of the Case
The case, Criminal Appeal No. 1162 of 2011 in the Supreme Court of India, involved the appellants Mallappa & Ors. and the State of Karnataka. Initially acquitted by the Trial Court, they were accused of murdering Marthandappa. The prosecution relied on testimonies from witnesses PW3 and PW4. The Trial Court, however, found their accounts unreliable due to inconsistencies and discrepancies. Despite this, the High Court reversed the acquittal, convicting the appellants based on the same testimonies. The central issue was the reliability of these witness statements.
Issues Involved
The reliability of PW3 and PW4’s testimonies. Evaluation of the Trial Court’s decision to acquit, considering perceived inconsistencies in witness conduct. Scrutiny of the High Court’s decision to convict based on the same testimonies despite the Trial Court’s acquittal.
Court’s Observation and Analysis
The Supreme Court’s analysis focused on the Trial Court’s skepticism towards PW3 and PW4’s testimonies. The High Court’s failure to identify legal errors in the Trial Court’s decision was criticized, emphasizing the importance of maintaining the presumption of innocence. The judgment delved into principles of circumstantial evidence, stressing the need for conclusive and consistent proof for guilt. The Supreme Court, after meticulous examination, concluded that the High Court’s decision lacked a comprehensive appreciation of the evidence, leading to the restoration of the Trial Court’s acquittal and the release of the appellants. The ruling underscored the commitment to a fair judicial process and the presumption of innocence.
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Written by- Komal Goswami