In a significant judgment on Monday, the Supreme Court emphasized the “presumption of innocence” for individuals acquitted by trial courts, stipulating that appellate courts should not overturn such decisions unless they exhibit “manifest illegality or perversity.” This ruling came as the apex court overturned the Chhattisgarh High Court’s decision that had previously convicted Jagdish Gond of his wife’s alleged murder.
The bench, consisting of Justices Sudhanshu Dhulia and K Vinod Chandran, restored the trial court’s acquittal of Gond. Justice Chandran, who penned the judgment, pointed out the lack of substantive evidence against Gond and noted that the high court had erred in reversing the acquittal based solely on an unproven alibi.
The Supreme Court’s verdict clarified, “It is trite that unless it is demonstrated that there is some manifest illegality or perversity in the conclusions recorded by the trial court while arriving at the finding of guilt of the accused, an acquittal ordinarily should not be reversed.” The judgment further added that if the trial court’s view to acquit is plausible, it should not be disturbed by the appellate court lightly.
The case originated from the death of Gond’s wife, with whom he had been married for two years. Her body was discovered by Gond on the morning of January 29, 2017. He immediately reported the incident to the police, leading to an investigation under Section 174 of the Code of Criminal Procedure for unnatural death. Although the postmortem report indicated a ligature mark on her neck, it did not conclusively establish the cause of death.
The trial court, citing the absence of definitive medical evidence and lack of corroborative circumstantial evidence, concluded the death was a suicide and acquitted Gond. However, the state appealed this decision, and the high court convicted Gond under Section 302 (murder) of the Indian Penal Code, imposing a life sentence. The high court’s judgment hinged on the principle of Section 106 of the Indian Evidence Act, which places the burden on Gond to explain the circumstances of the death due to their cohabitation.
