Substance over Form in Reversing Acquittals and the Primacy of Injured Eyewitness Testimony: Commentary on Sri Chikkegowda v. State of Karnataka

I. Introduction

The Supreme Court’s decision in Sri Chikkegowda & Ors. v. State of Karnataka etc., Criminal Appeal Nos. 541–543 of 2015 (with Criminal Appeal Nos. 1509–1510 of 2015), decided on 7 October 2025, is a significant pronouncement in criminal appellate jurisprudence. It squarely addresses:

the scope of appellate interference with an order of acquittal, and
the evidentiary value of an injured eyewitness vis-à-vis medical opinion.

Sixteen accused were tried for forming an unlawful assembly and committing the murder of Mohan Kumar, and for causing grievous hurt and outraging the modesty of his wife, Smt. Annapurna (PW‑1). The Trial Court acquitted all accused. The High Court partly reversed the acquittal, convicting seven accused (Accused Nos. 1–6 and 11) under Sections 143, 147, 148, 324, 302 read with 149 IPC, and confirming the acquittal of the remaining eight accused and on some of the more serious ancillary charges.

The convicted accused approached the Supreme Court challenging the High Court’s reversal of acquittal. The Supreme Court dismissed the appeals, affirming the High Court’s conviction.

Doctrinally, the judgment is important for three principal reasons:

It clarifies that an appellate court reversing an acquittal need not use ritualistic or “talismanic” language (such as explicitly saying the trial court’s view was “not a probable view”), so long as its reasoning clearly demonstrates that the acquittal was based on a perverse appreciation of evidence.
It reaffirms the primacy of trustworthy ocular testimony, particularly of an injured eyewitness, over medical opinion, especially where the medical evidence is broadly consistent and only differs on estimated time of death.
It strongly disapproves speculative, unsubstantiated defence theories which malign the character of a woman witness and underscores the principle that such a theory cannot be a valid foundation for acquittal without being properly put to the witness and backed by evidence.

II. Summary of the Judgment

1. Procedural History in Brief

Sixteen accused were charged with:
- unlawful assembly (Sections 143, 147, 148 IPC),
- murder (Section 302 read with 149 IPC),
- causing grievous hurt and other related offences (Sections 324, 326, 354, 341, 307 read with 149 IPC).
Accused No. 10 died during trial; proceedings against him abated.
The Sessions Court (in S.C. Nos. 144/2003 and 196/2003) acquitted all surviving 15 accused on 13.09.2010, chiefly by:
- disbelieving the injured eyewitness PW‑1,
- relying on a defence theory that PW‑1 had an illicit relationship with PW‑3 and was part of a conspiracy to kill her husband, and
- adopting the time of death suggested in cross‑examination of the autopsy doctor (PW‑17) to reject the prosecution’s timing.
The State filed Criminal Appeal No. 161/2011. PW‑1, the injured informant, filed two separate appeals (Crl. A. 335/2011 and 345/2011) against the acquittals.
The High Court, by judgment dated 29.10.2014:
- Confirmed acquittal of Accused Nos. 7, 8, 9, 12, 13, 14, 15, 16,
- Convicted Accused Nos. 1–6 and 11 under Sections 143, 147, 148, 324, 302 read with 149 IPC and sentenced them to life imprisonment under Section 302/149 IPC, with concurrent lesser sentences for other offences,
- Acquitted these convicted accused of offences under Sections 326, 354, 341, 307/149 IPC.
Accused Nos. 1–6 filed Criminal Appeal Nos. 541–543 of 2015 and Accused No. 11 filed Criminal Appeal Nos. 1509–1510 of 2015 before the Supreme Court.

2. Supreme Court’s Holding

The Supreme Court upheld the High Court’s judgment and dismissed the appeals, holding that:

The High Court was justified in reversing the trial court’s acquittal, as the latter was based on perverse and unsustainable reasoning.
The High Court correctly relied on the injured eyewitness PW‑1 and other corroborative material, and properly rejected the defence theory of an illicit affair and conspiracy.
Medical evidence regarding time of death was only approximate and could not override a consistent and credible ocular account.
The High Court’s cautious approach—acquitting several accused and discarding some parts of the prosecution version while accepting the rest—demonstrated a balanced and reasoned appreciation of evidence, warranting no interference.

III. Detailed Analysis

A. Factual Matrix and Evidence

1. The Incident

On 16.03.2003 at about 6:00 a.m., Mohan Kumar left his house carrying milk for the dairy. According to the prosecution, sixteen accused, with prior enmity against the deceased and certain prosecution witnesses, intercepted him and brutally assaulted him with deadly weapons, causing fifteen injuries as later recorded in the post-mortem report (Ex. P‑11).

When his wife, Smt. Annapurna (PW‑1), tried to shield him, she too was attacked and suffered grievous injuries. As villagers gathered, the assailants fled, discarding some weapons at the scene.

2. Medical Trail and First Information Report

The deceased and PW‑1 were taken first to the Primary Health Centre (PHC), Gandasi, where Dr. Sunil Kumar (PW‑18) examined them.
PW‑18 found the deceased alive but in a critical condition and referred him to a higher medical facility. Both injured were then taken to J.C. Hospital, Hassan, where the deceased was declared “brought dead”, and PW‑1 was treated.
While still at the PHC, the police arrived. PW‑1 narrated the incident; her oral statement was reduced into writing (Ex. P‑1), and she signed it. This formed the basis of FIR in Crime No. 38/2003 (Ex. P‑16).

3. Investigation and Prosecution Evidence

The investigation, substantially carried out by PW‑20, PW‑21, and PW‑23 (Investigating Officers), involved:

Preparation of the site plan and spot mahazar (Ex. P‑3, P‑29);
Conducting the inquest (Ex. P‑2);
Seizure of blood‑stained and plain earth (MO‑11, MO‑12) and discarded weapons (sickles, clubs, stones, rods – MO‑4 to MO‑10, MO‑13) through a series of seizure mahazars (Ex. P‑4 to P‑10);
Recovery of additional weapons pursuant to statements of accused under Section 27 of the Evidence Act;
Post-mortem by PW‑17 (Ex. P‑11) and wound certificate of PW‑1 by PW‑18 (Ex. P‑12);
Forwarding material objects to FSL, and obtaining forensic (Ex. P‑32) and serology reports (Ex. P‑33).

In all, the prosecution examined 23 witnesses (PWs 1–23), proved 33 documents (Ex. P‑1 to P‑33), and 13 material objects (MOs 1–13).

4. Defence Case

The defence examined:

Accused No. 1, Chikkegowda (DW‑1), and
Dr. Kumar (DW‑2).

Their core theory was radically different: PW‑1 allegedly had an illicit relationship with PW‑3; together with PW‑3’s associates, she had conspired to murder her husband in the early hours (around 3–4 a.m.), and then falsely implicated the accused, motivated by prior enmity.

The Trial Court accepted this theory sufficiently to raise doubt, and it also seized upon the cross‑examination of PW‑17 to conclude that death had occurred earlier than the time stated by PW‑1, thereby treating PW‑1’s testimony as unreliable.

B. Issues Before the Supreme Court

The appeals raised two principal legal issues:

Scope of appellate interference with acquittal: Did the High Court err in reversing the acquittal without expressly stating that the trial court’s view was “not a probable view” and without finding the trial court’s findings perverse?
Reliability and sufficiency of the injured eyewitness (PW‑1): Was PW‑1’s evidence, in light of the medical opinion on time of death and the alleged illicit relationship with PW‑3, untrustworthy such that the Trial Court’s acquittal deserved deference?

Ancillary issues included:

whether the difference in estimated time of death between ocular and medical evidence was fatal to the prosecution;
whether the defence theory based on alleged illicit relationship and conspiracy was tenable;
whether the High Court properly exercised its powers by selectively accepting and rejecting parts of the prosecution case.

C. Precedents Cited and Their Role

1. Precedents on Appellate Interference with Acquittals

On behalf of the appellants, reliance was placed on:

Muralidhar alias Gidda v. State of Karnataka, (2014) 2 SCC (Cri) 690;
Krishna @ Krishnappa v. State of Karnataka, Criminal Appeal No. 162 of 2009, decided on 14.11.2014.

These decisions articulate the well‑settled principles that:

In an appeal against acquittal, there is a “double presumption of innocence”—arising from the normal presumption before trial plus the acquittal by the trial court.
An appellate court is slow to interfere unless the trial court’s view is:
- manifestly illegal, or
- grossly erroneous or perverse, or
- such that no reasonable person would take it on the evidence.
If the trial court’s view is a reasonably possible or “probable” view of the evidence, the appellate court should ordinarily not substitute its own view merely because another view is also possible.

The appellants argued that the High Court failed to explicitly record that the trial court’s view was not a “probable view” and therefore erred in converting acquittal to conviction.

The Supreme Court, however, held that the substance of the High Court’s reasoning, not the form of its wording, is decisive. After examining the High Court’s analysis, the Supreme Court found that the High Court had in fact treated the trial court’s conclusions as perverse and unsustainable, even if it did not mechanically recite the expression "not a probable view".

2. Precedents on Ocular vs. Medical Evidence

On the issue of conflict between ocular evidence and medical evidence, the Supreme Court cited:

Darbara Singh v. State Of Punjab, (2012) 10 SCC 476:
The Court reiterated that unless the ocular version is totally irreconcilable with medical evidence, the former has primacy. Only when medical evidence completely rules out the possibility of the ocular account being true does the latter fall.
State of U.P. v. Hari Chand, (2009) 13 SCC 542:
It was held that oral evidence retains primacy unless it is wholly inconsistent and irreconcilable with medical evidence.
Pruthviraj Jayantibhai Vanol v. Dinesh Dayabhai Vala & Ors., (2022) 18 SCC 683:
The Court emphasized that ocular evidence is normally the best evidence unless there are compelling reasons to doubt its credibility.

These precedents underpinned the Court’s approach in Sri Chikkegowda: minor or explainable inconsistencies between the medical estimate of time of death and the eyewitness’s account cannot discredit a credible injured eyewitness.

D. The Court’s Legal Reasoning

1. On Appellate Reversal of Acquittal

The appellants’ first major contention was that the High Court did not explicitly record that the trial court’s view was not a probable view, hence it should not have reversed the acquittal. The Supreme Court rejected this, holding:

The High Court had meticulously analysed the trial court’s findings and found them unsustainable.
It identified clear errors in the trial court’s evaluation of PW‑1, its misunderstanding of medical evidence, and its acceptance of a speculative defence theory.
Thus, in substance, the High Court held that the trial court’s acquittal was based on perverse reasoning, even if it did not use the exact phrase “not a probable view”.
To insist on the use of a particular stock phrase would be to elevate form over substance. What matters is whether the appellate court’s reasons reveal that it found the acquittal legally unsustainable, not whether it used an exact formula of words.

This aspect of the judgment subtly but importantly clarifies that appellate courts are not bound by verbal formulas; they must adhere to the standard as a matter of substance, but they are not required to recite it in any particular language.

2. On the Credibility of the Injured Eyewitness (PW‑1)

The Supreme Court devoted considerable attention to the evidence of PW‑1, Smt. Annapurna — an injured eyewitness and the informant.

Key points in favour of PW‑1’s credibility were:

Her earliest version at the PHC (Ex. P‑1) was consistent with her trial testimony regarding:
- the timing of the incident (~6:00 a.m.),
- the manner of assault,
- the weapons used, and
- the identity and roles of the assailants.
She sustained grievous injuries documented in Ex. P‑12, proved by PW‑18. The defence:
- never suggested that the injuries were self‑inflicted or fabricated, and
- did not seriously contest the medical certificate.
In cross‑examination, the defence could not extract anything substantial to impeach her credibility.
Most importantly, despite basing their theory on her alleged illicit relationship with PW‑3, the defence never put this suggestion to PW‑1 herself in cross‑examination.

The Court highlighted a crucial procedural and evidentiary point: a party cannot build its entire case on a suggestion that has not been put to the principal witness concerned. The appropriate forum for challenging her character or suggesting a conspiracy would have been her cross‑examination; the failure to do so significantly undermined the defence theory.

The Court also reasoned that it is inherently implausible that:

an injured widow, who suffered serious, unchallenged injuries,
would falsely implicate 7 accused and exonerate the real culprits who killed her husband,
especially when there was admitted enmity giving the accused a strong motive to attack the deceased.

This reasoning draws on a long-standing line of cases which hold that an injured witness’s presence at the scene is difficult to dispute, and their evidence is entitled to great weight unless there are very strong reasons to reject it.

3. On the Alleged Illicit Relationship and Defence Conspiracy Theory

The trial court had been swayed by the defence argument that PW‑1 had an illicit relationship with PW‑3 and that both, along with PW‑3’s henchmen, had killed the deceased in the early hours. The Supreme Court and the High Court both found this theory wholly unsubstantiated and logically flawed.

Key reasons:

Chronology:
- PW‑9 (father of the deceased) stated in cross‑examination that the divorce proceedings of PW‑3 took place around 1995.
- The marriage of PW‑1 to the deceased occurred later, around 1996–97.
- Therefore, PW‑1 could not have possibly been the cause of PW‑3’s divorce; the alleged illicit relationship could not logically serve as the reason for the divorce.
Absence of cross-examination:
- As noted, no suggestion regarding such a relationship or conspiracy was put to PW‑1, the very person whose character was impugned.
- The only suggestion of an illicit relationship appeared in a question to PW‑9; mere suggestion to a collateral witness, without following it up with concrete evidence or confronting the main witness, lacks evidentiary weight.
Injuries to PW‑1:
- If PW‑1 were a conspirator, it is unlikely she would subject herself to grievous injuries merely to create a façade; the defence never even alleged that her injuries were self‑inflicted.
Absence of supporting evidence:
- No documentary or independent evidence was produced to support this theory—no prior complaints, no credible testimony, no consistent narrative.

The Supreme Court went so far as to say that the trial court should have condemned the defence’s unnecessary aspersions on PW‑1 instead of being influenced by them. This is an important affirmation that attacks on a woman witness’s character must not be lightly entertained, still less treated as a basis for acquittal without probative material.

4. On Ocular vs. Medical Evidence – Time of Death

A crucial plank of the Trial Court’s reasoning was a perceived inconsistency between:

PW‑1’s statement that the incident occurred around 6:00 a.m., and
an answer by PW‑17 (autopsy doctor) in cross‑examination that the death could have occurred between 3:00–4:00 a.m.

The Supreme Court carefully reconciled this:

Ex. P‑11 (post-mortem report) recorded that:
- post-mortem was conducted on 16.03.2003 between 3:00–4:00 p.m., and
- the death had occurred 10–12 hours prior to that.
Counting backwards 10–12 hours from 3–4 p.m. gives an estimated time of death around 5:00–6:00 a.m..
This estimate aligns well with PW‑1’s consistent account of a 6:00 a.m. incident.
Any suggestion in cross‑examination that death “could have” been at 3–4 a.m. is:
- only a possibility, not a definitive statement, and
- contrary to the doctor’s own recorded estimate in the post-mortem report.

The Court emphasized that time of death is always an approximation in medical testimony, with a margin of a couple of hours plus or minus. Absent a clear, irreconcilable conflict, medical opinion cannot displace a cogent, otherwise reliable eyewitness account.

5. Overall Evaluation of Evidence and the High Court’s “Grain from Chaff” Approach

The Supreme Court expressly endorsed the High Court’s approach of separating the grain from the chaff:

The High Court did not mechanically accept the entire prosecution version.
It:
- Confirmed the acquittal of 8 of the 16 accused (Nos. 7, 8, 9, 12–16);
- Rejected the charges of outraging modesty (Section 354 IPC) and attempt to murder (Section 307 IPC) despite finding the accused guilty of murder and grievous hurt; it held PW‑1’s injuries, though grievous, were not dangerous to life to sustain an attempt‑to‑murder charge;
- Relied only on those eyewitnesses whose testimony withstood scrutiny (notably PW‑1 and PW‑7), discarding others who appeared unreliable or exaggerated.

The Supreme Court also noted that:

The homicidal nature of the death was clearly established.
The FIR was promptly lodged and placed before the Magistrate without undue delay, reducing scope for concoction.
The medical, forensic, and recovery evidence (weapons, blood‑stained earth, etc.) corroborated the prosecution’s narrative and PW‑1’s version.
Formal witnesses, including doctors, panch witnesses, and Investigating Officers, were not declared hostile and were not discredited.

All these factors cumulatively justified the High Court’s conviction of Accused Nos. 1–6 and 11, and the Supreme Court saw “no ground to interfere.”

E. Doctrinal Significance and Impact

1. Substance over Formula in Appellate Review of Acquittals

One notable contribution of this judgment is its rejection of a formulaic approach to appellate reversal of acquittals. The Court confirms that:

The governing principle is that an appellate court may interfere with an acquittal where the trial court’s view is perverse, unreasonable, or contrary to the evidence.
However, it is not mandatory for the appellate court to recite the exact phrase “the trial court’s view was not a probable view”.
What matters is that the appellate judgment, on its face, shows that the trial court’s appreciation of evidence was such that a reasonable person could not have arrived at that conclusion.

This is likely to guide future appellate benches away from an overly formalist insistence on certain expressions and towards careful reasoning and articulation of why an acquittal is unsustainable.

2. Reaffirmation of Primacy of Injured Eyewitness Testimony

The judgment strongly reinforces that:

An injured eyewitness is a witness of very high evidentiary value. Their presence at the scene is rarely disputable.
Unless their evidence is inherently improbable or riddled with serious contradictions, courts should be slow to discard it.
Merely because there are minor inconsistencies with medical evidence regarding time or minor details, their testimony does not become unreliable, especially when the medical evidence is broadly consistent with their account.

This aligns with the larger body of jurisprudence under Section 134 of the Evidence Act: “quality, not quantity” of witnesses is what matters, and even a single reliable witness can suffice for conviction.

3. Ocular vs. Medical Evidence – Practical Clarification

By directly addressing the estimated time of death, the Court provides a practical clarification for criminal courts:

Estimates such as “death occurred 10–12 hours prior” must be treated as rough approximations, not precise timestamps.
Doctors’ statements in cross‑examination like “death could have occurred at 3–4 a.m.” are expressions of possibility, not definitive conclusions, especially when the written post-mortem report supports a different range.
Only when the medical evidence categorically excludes the ocular version (e.g., type or location of injuries making the alleged manner of assault impossible) should courts reject ocular testimony.

This guidance will be particularly important in cases where:

there is a small divergence between the eyewitness account and the medical estimate of timing, and
defence seeks to exaggerate such differences into a fatal contradiction.

4. Safeguarding the Dignity of Women Witnesses in Criminal Trials

The judgment has an important gender‑justice dimension. It implicitly recognizes that:

Defence strategies sometimes involve attacking the character of women witnesses, especially widows or complainants in serious offences, through allegations of immoral relationships.
Courts must be cautious not to give undue credence to such allegations unless they are:
- directly put to the witness in cross-examination, and
- supported by cogent, independent evidence.
Unsubstantiated character assassination cannot form the basis of acquittal; indeed, as the Supreme Court comments, the trial court ought to condemn such conduct rather than build its reasoning on it.

Going forward, this decision can be cited to counter defence attempts to rely on unpleaded or untested insinuations about a woman witness’s character as a shortcut to reasonable doubt.

5. Approach to Enmity and Motive

The Court observed that there was admitted enmity between the deceased and the accused group, including over issues of public land encroachment and access to a public road, where the deceased had opposed the accused and helped another villager.

This serves as a reminder of a familiar principle: enmity is a double‑edged sword.

It can provide a strong motive for the accused to commit the offence.
It can also provide a motive to falsely implicate.

Courts must, therefore, evaluate enmity with care; in this case, the injuries to PW‑1, the prompt FIR, and the corroborative evidence tipped the balance towards treating enmity as motive for the crime rather than as a basis to infer false implication.

F. Simplifying Key Legal Concepts and Terminology

1. Unlawful Assembly and Common Object (Sections 143, 147, 148, 149 IPC)

Section 143 IPC: Defines unlawful assembly as an assembly of five or more persons with a common object specified in Section 141 (e.g., committing an offence).
Section 147 IPC: Punishes rioting – use of force or violence by an unlawful assembly.
Section 148 IPC: Punishes rioting when members are armed with deadly weapons.
Section 149 IPC: Creates vicarious liability; if an offence is committed by any member of an unlawful assembly in prosecution of the common object (or a probable outcome thereof), every member of that assembly is guilty of that offence.

In this case, the Court upheld the conviction under Sections 143, 147, 148, 302/149 IPC, holding that the accused shared a common object to attack and kill the deceased.

2. Murder, Grievous Hurt, and Other Offences

Section 302 IPC: Punishment for murder.
Section 324 IPC: Voluntarily causing hurt by dangerous weapons or means (less serious than grievous hurt).
Section 326 IPC: Voluntarily causing grievous hurt by dangerous weapons (a more serious offence; here, the High Court seems to have acquitted the accused of this charge but convicted them under 324 IPC in relation to PW‑1).
Section 307 IPC: Attempt to murder – requires proof of intention or knowledge, coupled with an overt act, so dangerous that, if death had resulted, it would have been murder.
Section 354 IPC: Assault or criminal force to woman with intent to outrage her modesty.
Section 341 IPC: Wrongful restraint.

The High Court, and the Supreme Court by affirmation, drew fine distinctions:

It treated the attack on the deceased as murder (Section 302) committed in prosecution of a common object (Section 149).
It treated the injuries to PW‑1 as grievous but not life‑threatening, insufficient to prove intention to kill her, and, therefore, did not uphold the Section 307 (attempt to murder) conviction.
It also held that the evidence did not reliably establish a distinct act of outraging modesty under Section 354 IPC.

3. “Culpable Homicide Amounting to Murder”

The expression used in the opening part of the judgment refers to:

Culpable homicide – causing death with the requisite mental element (intention/knowledge); and
When it satisfies the conditions in Section 300 IPC, it becomes murder (punishable under Section 302 IPC).

Here, the sustained, deadly attack with dangerous weapons causing multiple injuries justified the classification as murder.

4. Procedural Concepts: FIR, Charge-Sheet, and Sections 173(2) CrPC & 27 Evidence Act

First Information Report (FIR):
- The initial information given to the police about the commission of a cognizable offence. It sets the criminal law in motion.
- Here, Ex. P‑1 was PW‑1’s complaint, and Ex. P‑16 is the FIR in Crime No. 38/2003, promptly registered on that basis.
Section 173(2) CrPC:
- Requires the Investigating Officer to submit a police report (charge‑sheet) on completion of investigation, stating the evidence collected and the offences made out.
- The IO did so here, which led to committal of the case to the Sessions Court.
Section 27, Indian Evidence Act:
- Provides that when a fact is discovered in consequence of information received from an accused in police custody, so much of the information as distinctly relates to the discovery is admissible, even though made in police custody.
- Weapons recovered at the instance of accused persons were admitted under this principle.

5. “Benefit of Doubt” and “Perverse” Findings

Benefit of doubt:
- In criminal law, if there is a reasonable doubt about the guilt of the accused, they must be acquitted.
- But the “doubt” must be reasonable – based on evidence and logic – not speculative, fanciful, or arising from misreading of evidence.
Perverse finding:
- A conclusion that no reasonable person would reach on the evidence, often by ignoring material evidence or relying on conjectures.
- Here, the trial court’s rejection of PW‑1’s testimony and acceptance of the illicit‑relationship theory, despite absence of cross‑examination or evidence, was treated as perverse.

6. “Separating Grain from Chaff”

This metaphor refers to the judicial technique of:

Accepting the reliable portions of the prosecution case that are adequately proved; and
Rejecting the unreliable or exaggerated portions, rather than discarding the entire case wholesale.

The High Court’s nuanced approach—convicting only some accused, acquitting others, and accepting only those eyewitnesses and charges supported by solid evidence—is a classic application of this principle.

IV. Critical Appraisal

The judgment in Sri Chikkegowda is doctrinally conservative in that it largely reaffirms existing principles rather than charting a new path. Yet, its importance lies in its clarity and application of those principles in a factually complex case.

Key strengths include:

A clear restatement that medical opinion on time of death is inherently approximate, avoiding an over‑literal approach that can produce unjust results.
A robust affirmation of injured eyewitness testimony and a warning against casually discarding it on speculative grounds.
A principled rejection of character‑based defence theories against women witnesses in the absence of proper cross-examination and evidence.
A realistic assessment of the High Court’s reasoning, focusing on substance rather than whether it used the correct stock phrases about “probable views”.

One might argue that the Supreme Court could have elaborated even more explicitly on the standard for appellate interference with acquittals, including a structured restatement of when exactly a “possible” but implausible view shades into perversity. Nonetheless, on the facts presented, the finding that the trial court’s approach was unsustainable is persuasive.

Overall, the decision adds to the body of case law guiding High Courts on how to responsibly reverse acquittals and reaffirms doctrinal anchors around injured witnesses and ocular‑medical evidence conflicts.

V. Conclusion: Key Takeaways

The Supreme Court’s dismissal of the appeals in Sri Chikkegowda v. State of Karnataka yields several clear and practical lessons for criminal law and procedure:

Appellate courts may reverse acquittals where trial court findings are perverse, without reciting any fixed verbal formula. The adequacy of reasoning, not the presence of specific phrases, is decisive.
Injured eyewitnesses are highly credible witnesses. Their evidence should not be rejected lightly, particularly when corroborated by prompt FIRs, medical reports, and objective evidence.
Ocular testimony normally prevails over medical opinion unless the medical evidence makes the eyewitness account impossible. Minor discrepancies, especially in estimated time of death, are not fatal.
Speculative and unsubstantiated defence theories, especially those that malign a woman witness’s character, cannot form the basis for acquittal unless put to the witness and supported by evidence.
Courts must separate grain from chaff, accepting reliable parts of the prosecution case and rejecting only the doubtful parts, rather than discarding the entire case due to some unreliable witnesses or exaggerated charges.

In sum, this judgment consolidates and applies foundational principles of criminal adjudication, ensuring that justice is not derailed by conjecture, technical misreadings of medical evidence, or untested character attacks. It stands as a useful precedent for trial and appellate courts alike in handling complex homicide cases involving multiple accused, injured witnesses, and contested medical timelines.