13 February 2025 Criminal Appeals & Suspension of Sentence >> Criminal Law   |   Murder Homicide >> Criminal Law  

The Supreme Court of India has expressed strong dissatisfaction with the Madhya Pradesh High Court's handling of a murder appeal, overturning an acquittal and ordering a fresh hearing. The case of The State of Madhya Pradesh v/s Girish Kumar., involves a man accused of murdering his pregnant wife, where the High Court's judgment lacked adequate reasoning and failed to properly re-evaluate the evidence.

The trial court had convicted the husband based on circumstantial evidence, including motive, last seen evidence, homicidal death within the house, and the accused's lack of a plausible explanation. However, the High Court, in its appeal judgment, merely outlined general principles of circumstantial evidence without addressing the specific findings of the trial court.

The Supreme Court criticized the High Court's failure to re-appreciate the evidence and explain why the trial court's conclusions were deemed erroneous. Emphasizing the duties of a first appellate court, the Supreme Court cited its previous ruling in State of Gujarat vs. Bhalchandra Laxmishankar Dave, which stressed the need for thorough re-evaluation of evidence in conviction appeals.

"It was expected of the High Court to explain as to why and on what basis it reached the conclusion that the incriminating circumstances looked into by the Trial Court for the purpose of holding the respondent herein guilty of offence were not sufficient enough to point a finger towards the guilt of the accused," the Supreme Court stated.

Consequently, the Supreme Court set aside the High Court's acquittal and remanded the case for a fresh hearing. The High Court has been directed to re-examine the appeal within three months, providing detailed reasoning for its decision. As the acquittal was overturned, the accused was ordered to furnish a fresh bail bond before the High Court. This decision underscores the importance of rigorous judicial review and the need for appellate courts to provide clear and comprehensive justifications for their rulings.