WHEN SUSPICION OVERREACHES PROOF: RESTORING THE SANCTITY OF ACQUITTAL IN CRIMINAL APPEALS

INTRODUCTION
In Tulasareddi @ Mudakappa & Anr. v. State of Karnataka & Ors., 2026 INSC 67, decided on 16 January 2026, the Supreme Court of India revisited core principles governing appeals against acquittal, circumstantial evidence and criminal conspiracy. The Judgment was delivered by a Division Bench comprising Justice Vipul M. Pancholi and Justice Sanjay Karol.
Setting aside the Karnataka High Court’s reversal of acquittal, the Supreme Court restored the Trial Court’s Judgment, reiterating that mere suspicion—however grave—cannot substitute proof and that appellate courts must exercise great circumspection before overturning a well-reasoned acquittal.

BRIEF FACTS
The prosecution case originated from a missing person Complaint lodged in December 2011 concerning one Martandgouda, who later came to be alleged as a victim of abduction, murder and destruction of evidence. Initially registered as a missing case, the investigation gradually took the shape of a murder prosecution based on alleged property disputes, strained family relations and suspected illicit relationships.
Six accused were charge-sheeted for offences under Sections 302, 120-B, 201, 506 read with Section 149 IPC. The prosecution relied primarily on:
1) a sole purported eyewitness (PW-5),
2) alleged confessional disclosures, and
3) a chain of circumstantial evidence including motive and recovery of the dead body.
After a full-fledged trial, the Sessions Court acquitted all accused in March 2019, holding that the prosecution failed to establish a complete and unbroken chain of circumstances. The High Court of Karnataka, however, reversed the acquittal in November 2023 and convicted Accused Nos. 1 to 4. This conviction was challenged before the Supreme Court.

ISSUES OF LAW
1) Under what circumstances can an appellate court interfere with a judgment of acquittal?
2) Whether the prosecution proved the case beyond reasonable doubt based on circumstantial evidence and alleged conspiracy.
3) Whether the High Court was justified in reversing a plausible view taken by the Trial Court.

ANALYSIS OF THE JUDGMENT
Limits on Appellate Interference with Acquittal
The Supreme Court emphatically reiterated the “double presumption of innocence” in favour of an acquitted accused—first under criminal jurisprudence and second reinforced by the Trial Court’s verdict. The Court held that an appellate court may interfere with an acquittal only when the findings are perverse, manifestly illegal or based on complete misreading or omission of material evidence.
If two reasonable views are possible, the appellate court must not substitute its own view merely because it finds another interpretation more persuasive. The High Court, the Supreme Court found, failed to record compelling reasons showing that the Trial Court’s view was impossible or unreasonable.

Unreliability of the Sole Eyewitness
A central pillar of the prosecution case was PW-5, projected as the lone eyewitness. The Supreme Court found multiple infirmities in his testimony:
1) his statement was recorded 21 days after the alleged incident,
2) he admittedly did not know the accused personally,
3) he remained silent despite alleged opportunities to raise alarm,
4) his testimony suffered from contradictions, and
5) he was partially declared hostile.
The Court held that unexplained delay, inconsistent versions and the witness’s own criminal antecedents rendered his testimony unsafe for sustaining a conviction, particularly in a case lacking corroboration.

Breakdown of the Circumstantial Chain
The prosecution’s case was purely circumstantial. The Supreme Court reiterated that such cases demand proof of a continuous, complete and exclusive chain of circumstances leading only to the guilt of the accused.
In the present case:
• the motive was speculative and rooted in civil disputes,
• alleged conspiracy lacked proof of prior meeting of minds,
• medical evidence contradicted the prosecution timeline, an
• recovery of the dead body was inadequately proved, with crucial witnesses not examined.
Each missing link weakened the prosecution case, making conviction legally untenable.

Misplaced Reliance on Disclosure Statements
The High Court had placed substantial reliance on disclosure statements leading to recovery under Section 27 of the Evidence Act. The Supreme Court cautioned that disclosure alone cannot sustain conviction unless discovery is clearly proved and supported by independent evidence.
Where the discovery itself is doubtful and supporting witnesses are absent, such reliance becomes legally fragile.

CONCLUSION
The decision in Tulasareddi @ Mudakappa v. State of Karnataka is a robust reaffirmation of foundational principles of criminal law. It underscores that criminal conviction demands certainty, not conjecture and that appellate zeal must not erode the sanctity of a reasoned acquittal.
By restoring the Trial Court’s Judgment, the Supreme Court has reinforced that:
• suspicion cannot replace proof,
• circumstantial evidence must be airtight, and
• appellate courts must respect plausible acquittals.
The ruling serves as a significant reminder that the criminal justice system’s credibility rests not in the number of convictions it secures, but in the fairness and discipline with which guilt is judicially determined.