Supreme Court Upholds Conviction in Karnataka Murder Case: Why Witness Testimony Beat Medical Evidence

In an appeal against acquittal, the Supreme Court reiterated that ocular evidence prevails over medical opinion unless irreconcilable. It held that the Trial Court’s view was perverse for discarding the injured eyewitness’s consistent testimony based on speculative defenses and minor contradictions, thus rightly upholding the High Court’s conviction.

Facts Of The Case:

On March 16, 2003, at around 6:00 a.m., Mohan Kumar was assaulted by a group of sixteen accused persons when he was leaving his house in the village to deliver milk. The attackers, armed with dangerous weapons, inflicted fatal injuries on him. His wife, Smt. Annapurna (PW-1), who intervened to save him, also sustained grievous injuries. The accused fled upon the arrival of other villagers. The injured were first taken to a Primary Health Centre and then to a hospital, where Mohan Kumar was declared dead. PW-1 gave her statement to the police at the health centre, leading to the registration of the FIR. The Trial Court acquitted all accused, doubting PW-1’s testimony based on medical opinion about the time of death and an unsubstantiated defense theory of her illicit relationship with another witness. The High Court reversed the acquittal, convicting seven accused for murder and other charges. The Supreme Court upheld the High Court’s judgment, emphasizing the primacy of credible ocular evidence over medical estimation and rejecting baseless defenses.

Procedural History:

The procedural history of the case began with the Trial Court (Sessions Court) acquitting all fifteen surviving accused of charges including murder. The State of Karnataka and the informant then filed separate appeals before the High Court. The High Court, vide a common judgment, partly allowed the appeals—it confirmed the acquittal of eight accused but convicted the remaining seven (Accused Nos. 1 to 6 and 11) under various sections of the IPC read with Section 149. Aggrieved by their conviction, these seven accused filed appeals before the Supreme Court. The Supreme Court, after hearing the parties and scrutinizing the record, dismissed the appeals and upheld the conviction and sentence awarded by the High Court, finding no perversity or error in its judgment.

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Court Observation:

The Supreme Court made several key observations. It held that ocular testimony, especially of an injured eyewitness, prevails over medical evidence unless irreconcilable, and the medical estimate of the time of death could not override PW-1’s consistent account. The Court found the Trial Court’s reasoning perverse for discarding PW-1’s reliable testimony based on an unsubstantiated defense theory of an illicit relationship and a minor discrepancy in timing. It affirmed the High Court’s balanced scrutiny, which correctly separated credible evidence from chaff, and reiterated that an appellate court can reverse an acquittal if the trial court’s view is manifestly unreasonable or based on a misappreciation of evidence.

Final Decision & Judgement:

The Supreme Court dismissed the criminal appeals filed by the convicted accused. It upheld the judgment of the High Court, affirming the conviction of the appellants (Accused Nos. 1 to 6 and 11) for offences including murder (Section 302 read with Section 149 IPC) and other charges. The Court found no merit in the challenges against the High Court’s reversal of the Trial Court’s acquittal, holding that the High Court’s view was balanced, based on a correct appreciation of evidence, and that the Trial Court’s decision to extend benefit of doubt was perverse. The appellants were directed to continue serving their sentences, primarily life imprisonment.

Case Details:

Case Title: Sri Chikkegowda & Ors. vs. State of Karnataka Etc. 
CITATION: 2025 INSC 1213 
Criminal Appeal No(s): Criminal Appeal Nos. 541-543 of 2015 
Date of Judgement: October 07, 2025.
Judges/Justice Name: Justice Vikram Nath &  Justice Sanjay Karol, and Justice Sandeep Mehta
Download The Judgement Here

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