Supreme Court Reinstates Acquittal: Circumstantial Evidence, Unreliable Eyewitnesses & Limits on Appellate Review

lawsymptoms
Jan 18
3 min read

In Tulasareddi @ Mudakappa & Anr. v. State of Karnataka (2026 INSC 67), the Supreme Court reaffirmed foundational principles governing criminal appeals against acquittal and restored the trial court’s judgment acquitting the accused of murder and conspiracy charges. The ruling is a significant restatement of the law on circumstantial evidence, credibility of witnesses, and the limited scope of appellate interference.

Background of the Case

The case concerned the disappearance of Martandgouda in December 2011, which was initially registered as a missing person complaint. Subsequent investigation converted it into a murder case based on alleged land disputes, strained personal relationships, and claims of conspiracy. While the trial court acquitted all accused in 2019 citing serious evidentiary gaps, the Karnataka High Court reversed the acquittal in 2023 and convicted accused nos. 1 to 4.

The Supreme Court was called upon to examine whether the High Court was justified in overturning a “plausible view” taken by the trial court.

Supreme Court’s Analysis

The Court found that the prosecution case rested almost entirely on circumstantial evidence and a single purported eyewitness (PW-5). On close scrutiny, the Court found PW-5’s testimony to be unreliable due to:

a 21-day unexplained delay in disclosing the incident,
material contradictions between statements under Sections 161 and 164 CrPC,
absence of corroboration,
failure to raise alarm or inform authorities despite alleged presence at the crime scene, and
admitted criminal antecedents.

The Court also noted inconsistencies between medical evidence and the prosecution timeline, observing that the post-mortem opinion did not support the claim that death occurred on the date alleged by the prosecution.

Importantly, the alleged criminal conspiracy was held to be unproven, particularly since the High Court itself upheld acquittal of accused nos. 5 and 6, thereby weakening the prosecution’s theory of a unified conspiracy.

Reaffirmation of Law on Appeals Against Acquittal

The Supreme Court strongly reiterated that appellate courts must exercise restraint while reversing acquittals. It held that merely because another view is possible, a conviction cannot be substituted for an acquittal.

Key Quotations from the Decision (Decision & Reasoning Part)

On unreliability of the sole eyewitness

“Looking to the aforesaid aspects, it can be said that PW-5 can be said to be a planted witness.” (para 20)

“The sole so-called eyewitness, PW-5, cannot be said to be reliable and the other circumstances upon which the prosecution has placed reliance are insufficient to conclude that the accused have committed the alleged offences.” (para 23)

On failure of circumstantial evidence

“The prosecution has failed to complete the entire chain of circumstances from which it can be established that the accused had committed the alleged offences.” (para 23)

On medical evidence not supporting prosecution

“The medical evidence also does not fully support the case of the prosecution and raises doubt.” (para 22)

On conspiracy not being proved

“The prosecution has failed to prove the aforesaid aspect by leading cogent evidence and in fact the High Court has also not believed the story of conspiracy…” (para 25)

On appellate interference with acquittal

“If two reasonable conclusions are possible on the basis of the evidence on record, the Appellate Court should not disturb the findings of acquittal recorded by the Trial Court.” (para 29)

“If the view taken is a possible view, the Appellate Court cannot overturn the order of acquittal on the ground that another view was also possible.” (para 29)

Final holding

“The judgment and order dated 28.11.2023 passed by the High Court of Karnataka is hereby set aside and the judgment and order of the Trial Court dated 30.03.2019 is restored.” (para 31)