The Supreme Court heard criminal appeals challenging the High Court of Karnataka's judgment that reversed the Trial Court's acquittal and convicted the appellants for murder, conspiracy, destruction of evidence, and criminal intimidation. The case involved the disappearance and alleged murder of Martandgouda in 2011, with prosecution based on circumstantial evidence including alleged motive from civil disputes, last seen theory, and recovery. The Trial Court had acquitted all accused in 2019, finding the evidence insufficient to form a complete chain. The High Court reversed this in 2023, convicting four accused. The Supreme Court examined whether the High Court properly interfered with the acquittal and whether the circumstantial evidence met legal standards. The Court held that the prosecution failed to prove a complete chain of circumstances, the motive was speculative, and crucial links were missing. The High Court's interference was unjustified as the Trial Court's view was plausible. The Supreme Court restored the Trial Court's acquittal, allowing the appeals and directing the appellants' release.
Criminal Law-- Indian Penal Code, 1860-- Sections 302, 120B, 506 and 34-- Two appeals-- Initially application for missing of deceased given-- Subsequently allegations of conspiracy, abduction, murder and disappearance of evidence relating to deceased-- Acquittal of appellants/accused from charges-- Appeal against acquittal filed before high court-- High court set aside judgment of acquittal and convicted appellants u/s 302 of IPC-- Appellants/accused no. 1 to 3 challegend their conviction by way of two appeals before supreme court-- Non examination of important witneeses who have recovered dead body of deceased from canal-- So-called projected eye witness PW-5 did not inform the police about incident for a period of 21 days-- Accused were totally stranger for so-called eye witness PW-5-- Criminal antecedents against PW-5-- Medical evidence did not supported the case of prosecution as contradiction in the timing of death of deceased-- Imcomplete chain of circumstances- Conviction cannot be solely recorded on the basis of so-called confessional statements-- Discovery of dead body not proved-- Limited scope of interference in an order of acquittal-- If two views are possible on the basis of evidence on record, the appellate court should not disturb the findings of acquittal recorded by trial court-- Conviction set aside-- Appeals allowed
Para-- 16, 20, 22, 23, 27, 28, 29
The Supreme Court allowed the appeals, set aside the High Court's conviction, and restored the Trial Court's judgment acquitting all accused. The appellants were directed to be released forthwith if not required in any other case.
Citation: 2026 LawText (SC) (01) 62
Case Number: Criminal Appeal Nos. 2120-2121 of 2024, Criminal Appeal Nos. 2542-2543 of 2024
Date of Decision: 2026-01-16
Case Title: Whether the High Court was justified in reversing the Trial Court's acquittal and convicting the appellants based on circumstantial evidence that allegedly formed an incomplete chain
Before Judge: Vipul M. Pancholi, J. , Sanjay Karol, J.
Equivalent Citations: 2026 INSC 67
Appellant: Tulasareddi @ Mudakappa & Anr., Veerupakshagouda
Respondent: The State of Karnataka & Ors.
Nature of Litigation: Criminal appeals challenging conviction for murder, conspiracy, destruction of evidence, and criminal intimidation
Remedy Sought: Appellants seeking setting aside of High Court conviction and restoration of Trial Court acquittal
Filing Reason: High Court reversed Trial Court's acquittal and convicted appellants under IPC sections
Previous Decisions: Trial Court acquitted all accused in 2019 -- High Court convicted accused nos. 1-4 in 2023 while confirming acquittal of accused nos. 5-6
Issues: Whether the High Court was justified in interfering with the Trial Court's acquittal and convicting the appellants based on circumstantial evidence Whether the prosecution established a complete chain of circumstances proving guilt beyond reasonable doubt
Submissions/Arguments: Prosecution relied on circumstantial evidence including motive from civil disputes, last seen theory, and recovery Defense contended that evidence was insufficient and chain of circumstances was incomplete Appellants argued that High Court erred in reversing acquittal without finding perversity in Trial Court's view
Ratio Decidendi: In cases based solely on circumstantial evidence, the prosecution must establish a complete and unbroken chain of circumstances pointing unequivocally to the guilt of the accused. Mere suspicion, however strong, cannot substitute proof. Appellate courts should not lightly interfere with acquittals unless the Trial Court's view is perverse or impossible. The chain must be complete with no missing links.
Judgment Excerpts: The Trial Court recorded findings that the prosecution had failed to establish a complete and unbroken chain of circumstances pointing only towards the guilt of the accused The Trial Court specifically held that mere suspicion, however strong, could not take the place of proof, particularly in a case based solely on circumstantial evidence
Procedural History: FIR registered in 2011 for missing person -- Charge-sheet filed against six accused -- Trial Court acquitted all accused in 2019 -- High Court convicted accused nos. 1-4 in 2023 -- Supreme Court appeals filed in 2024
