Supreme Court Restores Trial Court Acquittal, Sets Aside Karnataka High Court Conviction in Canal Death Case

A bench of Justices Sanjay Karol and Vipul M. Pancholi heard appeals by three accused challenging the Karnataka High Court’s November 28, 2023 judgment that quashed a trial court acquittal and convicted them for offences including murder and criminal conspiracy arising from the disappearance and death of Martandagouda. The appeals arose from competing contentions over the sufficiency and reliability of eyewitness evidence, confessional statements and circumstantial links relied upon by the High Court.

The Supreme Court allowed the appeals, set aside the High Court judgment and restored the trial court’s order of acquittal dated March 30, 2019. The Court held that the High Court had erred in overturning a plausible view taken by the trial court and that the prosecution failed to establish a complete chain of circumstantial evidence pointing solely to the guilt of the appellants. The Court emphasised established principles governing interference in acquittal appeals and observed the limits on appellate reappraisal of acquittals. The Court, in its reasoning, observed: "From the aforesaid decisions rendered by this Court, it can be said that 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. ... the appellate court can interfere with the order of acquittal only if it comes to a finding that the only conclusion which can be recorded on the basis of the evidence on record was that the guilt of the accused was proved beyond a reasonable doubt and no other conclusion was possible."

Background The prosecution case arose from a missing person complaint lodged on December 16, 2011 after Martandagouda went missing on December 11, 2011. FIR and subsequent investigation named six accused, alleging a conspiracy motivated by land disputes and personal animosities, and contended that the deceased was abducted, murdered and his body dumped in a canal. A charge-sheet charged the accused under Sections 143, 147, 120-B, 364, 302, 201, 506 and 149 IPC; the Sessions Court tried the matter as Sessions Case No.37/2012.

At trial the prosecution examined 22 witnesses and produced documentary exhibits. Its case principally rested on the deposition of PW-5, a tempo-trax driver described as the “sole eye-witness”, confessional/disclosure statements by certain accused and circumstantial material including motive, last-seen theory and the recovery of the body on January 4, 2012. The trial court acquitted all accused on March 30, 2019, holding that "mere suspicion, however strong, could not take the place of proof" and that the prosecution had not established an unbroken chain of circumstances. The High Court allowed acquittal appeals by the State and complainant, convicted accused nos.1–4 and sentenced them to life terms; it confirmed acquittal of accused nos.5–6.

Before the Supreme Court, appellants contended that the eyewitness PW-5’s statements were recorded belatedly after arrests, contained contradictions, and did not implicate accused no.1; that medical evidence did not support the prosecution’s timeline; and that confessional statements and discovery of the body were not proved reliably. The State relied on PW-5’s Section 164 statement, post-mortem opinion that death resulted from manual strangulation, and discovery disclosures said to fall under Section 27 Evidence Act.

The Supreme Court found significant infirmities: PW-5’s delayed statement and admission of criminal antecedents cast doubt on his reliability; material witnesses who recovered the body were not examined; the post-mortem timing did not fully support the prosecution’s timeline; and the prosecution failed to complete the chain of circumstances. Applying settled precedents, the Court held that the High Court had not shown that the trial court’s view was unsupportable. The apex court set aside the High Court judgment, restored the trial court acquittal and ordered the appellants’ immediate release if not required in other matters.

Case Details: Case No.: 2026 INSC 67; Criminal Appeal Nos. 2120-2121 of 2024 and 2542-2543 of 2024 Case Title: Tulasareddi @ Mudakappa & Anr. v. The State of Karnataka & Ors.; Veerupakshagouda v. The State of Karnataka Appearances: For the Petitioner(s): Counsel not specified in the reported judgment For the Respondent(s): Learned Additional Advocate General for the State (name not specified); counsel for the informant (name not specified)