Murder Acquittal: SC Says Appellate Court Cannot Interfere Merely Because Another View Is Possible

The Supreme Court has held that an appellate court should not interfere with an order of acquittal if the view taken by the high court is a possible view based on the material on record, observing that an acquittal strengthens the presumption of innocence.

A Bench of Justices Ujjal Bhuyan and Atul S Chandurkar made the observation while dismissing an appeal filed by the State of Himachal Pradesh against the acquittal of accused Moti Ram in a murder case.

Court held that material contradictions in the testimonies of eyewitnesses regarding the overt act attributed to the accused, coupled with unexplained discrepancies concerning the physical condition of the recovered weapon, were sufficient to give the accused the benefit of doubt.

Why did the Supreme Court uphold acquittal?

Court found that the view taken by the high court was a possible view supported by the material on record and that there was no perversity in its appreciation of evidence.

Moti Ram, along with Man Singh, had faced trial for the offence punishable under Section 302 read with Section 34 of the Indian Penal Code [corresponding to Section 103 read with Section 3(5) of the BNS] for allegedly murdering Beli Ram on April 25, 2012.

The Sessions Court, by its judgment dated May 2, 2013, convicted both accused and sentenced them to life imprisonment under Section 302 read with Section 34 of IPC.

Moti Ram challenged the conviction before the high court. On August 19, 2014, a division bench of the high court allowed the appeal and acquitted him of the charges.

What was the prosecution's case?

The prosecution alleged that Beli Ram was dragged out of a room during a religious function at his house. Moti Ram, who was allegedly carrying a knife, stabbed Beli Ram in the chest. Beli Ram fell down and later succumbed to his injuries.

The State challenged the high court's acquittal before the Supreme Court, arguing that the high court had wrongly interfered with the "well reasoned" judgment of the sessions court on the basis of what it described as minor inconsistencies and contradictions in the eyewitness testimonies.

The State also argued that the seizure of the knife had been proved and should have been taken into consideration by the high court.

When can an appellate court interfere with an acquittal?

The Supreme Court said that the scope for interference in an appeal against an acquittal is limited.

"The scope for interference by the court in an appeal challenging an order of acquittal is circumscribed" by whether the findings are perverse or based on material that is not available on record, resulting in a wholly untenable conclusion, the Bench said.

However, where an appellate court, after reappreciating the evidence, gives the accused the benefit of doubt or finds the evidence insufficient to sustain the conviction, interference is not warranted merely because another view of the case is possible, it added.

Court further observed that an order of acquittal strengthens the presumption of innocence in favour of the accused.

What discrepancies did the high court find in the evidence?

The Bench noted that the High Court had considered various discrepancies in the depositions of the prosecution witnesses before granting Moti Ram the benefit of doubt.

Among other grounds, the high court had noted from the depositions of three prosecution witnesses that A2-Man Singh was the aggressor, while A1-Moti Ram was not found to have threatened anyone.

The high court also noted that although around 10-15 people had gathered at the place of the incident, none of them came forward to stop the scuffle between Moti Ram, Man Singh and Beli Ram.

There were also doubts regarding the knife allegedly recovered in connection with the crime.

No fingerprint was found on the knife, and no attempt had been made to locate fingerprints on it. The high court, therefore, found there was a doubt as to whether the knife was the same weapon that was allegedly recovered from the spot.

After reappreciating the evidence, the Supreme Court agreed with the high court's approach.

"On a reappreciation of the deposition of witnesses, we find that the view taken by the high court is a possible view which is supported by the material on record," the Bench said.

Court said it did not find any perversity in the high court's appreciation of evidence, although the prosecution evidence did raise some doubt regarding Moti Ram's complicity.

"We, therefore, find that the high court was justified in acquitting A1 from the offence with which he was charged," the Bench held.

The Supreme Court accordingly dismissed the appeal filed by the State and held that the high court's judgment of acquittal did not warrant interference under Article 136 of the Constitution.

Case Title: State of Himachal Pradesh Vs Moti Ram

Bench: Justices Ujjal Bhuyan and Atul C Chandurkar

Date of Judgment: July 24, 2026