Conviction Without Evidence? SC Slams High Court for Overreach in Acquittal Reversal

In a deeply considered and sternly reasoned judgment, the Supreme Court in Renuka Prasad v. State Represented by Assistant Superintendent of Police has once again underscored the foundational principles of criminal justice: the presumption of innocence, the need for legal evidence, and the inviolable standards of proof. Reversing the conviction of six individuals who had been found guilty by the High Court under Section 302 read with Section 120-B IPC,

the Supreme Court restored their acquittal as originally ordered by the Trial Court. The case is not just a textbook reiteration of procedural safeguards it is a vivid commentary on the perils of speculative justice.

The prosecution narrative revolved around a brutal murder, allegedly orchestrated by the first accused, A1, in the backdrop of a bitter family dispute over the division of educational institutions. According to the case built by the investigating officers, A1 hired contract killers through intermediaries, including an advocate (A7), who allegedly arranged the execution of the murder.

The deceased, once aligned with A1, had shifted allegiance to A1’s brother (PW4), escalating the rivalry and purportedly triggering the fatal conspiracy.

The killing, carried out in front of the deceased’s son (PW8), formed the emotive fulcrum of the case.

Yet the prosecution's case unravelled spectacularly at trial. Of 87 witnesses presented, 71 turned hostile including the eye-witness PW8, the deceased’s own son, who failed to identify the accused or the weapons.

Even those present immediately after the attack failed to support the identification or the supposed motive. Witnesses to key events from the planning and preparation to the recovery of weapons and cash resiled from their earlier statements. The Trial Court, noting this comprehensive collapse of evidentiary support, acquitted the accused.

However, the High Court overturned this acquittal, leaning heavily on the investigating officers' testimonies and the Section 161 CrPC statements of witnesses statements that had been denied in court.

The Supreme Court found this approach not only flawed but legally impermissible. Section 161 statements are not substantive evidence and cannot be relied upon unless the witness affirms them in the witness box. Relying on the investigating officer's version of what witnesses allegedly said during investigation cannot cure the evidentiary vacuum at trial.

Further, the Court chastised the High Court for treating confession statements under Section 27 of the Evidence Act as primary inculpatory evidence, especially when the confessions were made by a co-accused and not corroborated independently.

The Court reaffirmed the canonical position from Pulukuri Kottaya and later affirmed in Navjot Sandhu that only the part of a confession which leads directly to a discovery of fact, and not the confessional narrative itself, is admissible.

In this case, weapons and clothes were recovered on the confession of a co-accused (A3), not from the actual perpetrators (A5 & A6), and no link was established between the accused and the items recovered. Crucially, the recovered clothes were never even shown to the supposed eyewitnesses for identification.

The judgment is particularly scathing about the High Court’s misplaced faith in “moral conviction” as a substitute for legal proof. By relying on assumptions, unproven motives, and hostile witness statements recited by police, the High Court had effectively attempted to convict the accused “somehow” a judicial posture the Supreme Court decisively condemned. Truth, the Court said, may be elusive, but cannot be pursued at the cost of foundational criminal law principles.

In this ruling, the Supreme Court has not merely acquitted the accused it has reaffirmed the discipline of adjudication. It has reminded the judiciary that suspicion, no matter how grave, cannot take the place of evidence. It has restored the normative primacy of fair trial rights, even in cases where the crime is brutal and the victims evoke sympathy.

Ultimately, Renuka Prasad is a sobering reminder that the rule of law stands tallest when courts resist the temptation to do justice through shortcuts. Acquittals, like convictions, must be respected when grounded in due process. And where evidence fails, even the most tragic crime must end in release—not retribution.