The Supreme Court acquitted the accused in a murder case, ruling that the prosecution failed to prove guilt beyond reasonable doubt due to the hostile testimony of 71 out of 87 witnesses. The Court held that reliance on police testimony and Section 161 CrPC statements violated Section 162 CrPC, and recoveries under Section 27 of the Evidence Act were inadmissible without independent corroboration. The judgment reaffirmed that acquittals can only be overturned if the trial court’s view was wholly unreasonable, emphasizing the presumption of innocence.
Facts Of The Case:
The case involved the brutal murder of an employee allegedly orchestrated by his former employer (A1) due to professional rivalry. On April 28, 2011, the victim was hacked to death in front of his 15-year-old son (PW8) near Bengaluru. The prosecution claimed A1 conspired with five others (A2-A6), including contract killers, motivated by the victim’s support to A1’s brother in a family dispute over educational institutions. Despite 87 witnesses being examined, 71 turned hostile during trial, including the eyewitness son who failed to identify the assailants. The prosecution relied heavily on police testimony about alleged confessions and recoveries – including weapons, blood-stained clothes (matching the victim’s blood group), and cash bundles from accused persons – but all panch witnesses disowned the seizure mahazars.
While the Trial Court acquitted all accused due to insufficient evidence, the Karnataka High Court reversed this, convicting A1-A6 under Section 302/120B IPC based on police evidence. The Supreme Court, however, found the High Court’s reliance on Section 161 statements and uncorroborated police testimony illegal under Section 162 CrPC, and held the Section 27 recoveries inadmissible as they lacked connection to the crime. With no legally admissible evidence, the SC restored the acquittal.
Procedural History:
The procedural history of Renuka Prasad v. State began with the 2011 murder case being tried before the Bengaluru Sessions Court, which acquitted all accused in 2023 due to insufficient evidence after 71 of 87 witnesses turned hostile. The State appealed to the Karnataka High Court, where a Division Bench in 2024 reversed the acquittal and convicted A1–A6 under Sections 302/120B IPC, primarily relying on police testimony about recoveries and Section 161 CrPC statements. The accused then filed appeals before the Supreme Court (Criminal Appeal Nos. 3189–3190 of 2023 and connected matters). In its May 9, 2025 judgment, the Supreme Court set aside the High Court’s decision, holding that the conviction was based on inadmissible evidence (uncorroborated police statements and improper reliance on Section 27 recoveries) and restored the Trial Court’s acquittal, emphasizing the prosecution’s failure to prove guilt beyond reasonable doubt. The accused were ordered to be released if not wanted in other cases.
Court Observation:
The Supreme Court made critical observations while overturning the High Court’s conviction in Renuka Prasad v. State. It emphasized that the prosecution’s case collapsed due to 71 of 87 witnesses turning hostile, including the eyewitness son (PW8) who failed to identify the assailants. The Court held that the High Court erred in relying on police testimony about Section 161 CrPC statements, violating Section 162’s bar against using such statements as substantive evidence. It further ruled that recoveries under Section 27 of the Evidence Act (weapons, blood-stained clothes) were inadmissible as they lacked independent corroboration and were disconnected from the accused.
The Bench reiterated that acquittals can only be reversed if the trial court’s view was “manifestly unreasonable,” which was absent here. Crucially, it condemned the High Court’s approach of substituting the prosecution’s failed evidence with police narratives, stressing that “moral conviction” cannot replace legal proof in criminal trials. The judgment reaffirmed the presumption of innocence and the prosecution’s burden to establish guilt beyond reasonable doubt through legally admissible evidence.
Final Decision & Judgement:
The Supreme Court, in its final judgment dated May 9, 2025, allowed the criminal appeals and acquitted all accused, overturning the Karnataka High Court’s conviction order. The Bench comprising Justices Sudhanshu Dhulia and K. Vinod Chandran held that the prosecution failed to establish guilt beyond reasonable doubt, as the case rested entirely on:
-
Inadmissible evidence (statements under Section 161 CrPC, which cannot substitute witness testimony under Section 162);
-
Uncorroborated police claims about recoveries (weapons, clothes) under Section 27 of the Evidence Act, lacking nexus to the crime;
-
Hostility of 71 witnesses, including the eyewitness son, which crippled the prosecution’s narrative.
The Court restored the Trial Court’s acquittal, ruling that the High Court committed a “grave error” by relying on presumptions and police testimony over substantive legal evidence. It emphasized that reversing an acquittal requires “compelling and manifestly justifiable reasons,” absent here. The accused were ordered to be released immediately if not wanted in other cases. The judgment reaffirmed core principles: presumption of innocence, the prosecution’s burden of proof, and the bar on using investigative statements as evidence. It serves as a stern reminder that convictions cannot be sustained on moral suspicion or procedural irregularities.
Case Details:
Case Title: Renuka Prasad vs. The State Represented by Assistant Superintendent of Police Citation: (2025) INSC 657 (Supreme Court of India) Appeal Numbers: Criminal Appeal Nos. 3189–3190 of 2023 (Primary appeals by A1) Criminal Appeal No. 3399 of 2024 Criminal Appeal Nos. 85–86 of 2024 (Connected appeals by other accused) Date of Judgment: May 9, 2025 Bench: Justice K. Vinod Chandran (Author of the judgment) & Justice Sudhanshu Dhulia (Concurring)