Jaipur High Court Affirms Acquittal in Alleged Murder Case: No Interference Warranted When Trial Court’s View Is a “Possible View” on Evidence
Case Title: Raju Devi Bunkar v. State of Rajasthan & Anr., D.B. Criminal Appeal (Db) No. 302/2025 — Date of Judgment: 08/12/2025
The present appeal arises from the acquittal of respondent Govind in offences including Sections 302, 342 and 323 IPC by the trial court and the subsequent challenge to that order before the High Court. The factual matrix, as recorded in the judgment, shows that on 03.11.2012 a report (P.I.-11) was lodged regarding the death of Uttam Kumar and competing versions were placed on record by family witnesses and the accused’s side; the investigation culminated in charge-sheeting under various sections and ultimately resulted in the trial court recording acquittal on 24.04.2025.
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The appellate record recounts that multiple witnesses were examined in trial — including eyewitnesses, local persons and medical evidence — and that there were significant divergences in the statements and respective versions about the events of 03.11.2012. The High Court’s summary of evidence (see pages 4–6 of the file) highlights inconsistencies in eyewitness accounts, gaps in forensic/medical corroboration for homicidal assault, and particulars such as timing, injuries and the presence or absence of demonstrative indicia on the deceased’s person that bear on the reliability of the prosecution case.
The learned trial court’s approach, as noticed by the Division Bench, was to closely evaluate the oral testimony presented and to find that the prosecution failed to discharge the burden of proving guilt beyond reasonable doubt; the trial court therefore returned a view favourable to the accused. The High Court adverted to the trial court’s reasoning, including the manner in which the trial court treated the discrepancies and the nature of corroboration tendered, and placed those findings in the context of appellate interference doctrine.
In applying established appellate principles, the Bench relied on the Supreme Court guidance cited in the judgment (Babu Sahebagouda Rudragoudar v. State of Karnataka and related authority), reiterating that an appellate court can disturb an acquittal only where the trial court’s view is patently perverse, is based on misreading or omission of material evidence, or where no two reasonable views are possible — in short, where the only possible conclusion from the record is guilt beyond reasonable doubt. The judgment reproduces and applies these principles to the facts of the case (see paragraph 13–14 of the judgment).
After a considered re-appreciation of the record, the Division Bench concluded that the trial court’s view was a possible view which could reasonably be drawn from the evidence on record and that the scope for interference was therefore absent. The High Court recorded that neither legal nor factual infirmity of the nature required to overturn an acquittal was made out on the material before it, and accordingly the appellate challenge was dismissed and the trial court’s order of acquittal dated 24.04.2025 was held to be sustainable.
The judgment directs that the decree be communicated to the trial court and is confined to the determination of the appeal under the criminal appellate jurisdiction; it does not re-open factual findings beyond the permissible limits of appellate review as spelled out in the authorities relied upon by the Bench.
