Tulasareddi @ Mudakappa & Anr. v. State of Karnataka & Ors. (with Veerupakshagouda v. State of Karnataka)

 Case Details

Citation: 2026 INSC 67
Decided on: 16 January 2026
Case Title: Tulasareddi @ Mudakappa & Anr. v. State of Karnataka & Ors. (with Veerupakshagouda v. State of Karnataka)
Court: Supreme Court of India
Bench: Sanjay Karol J., Vipul M. Pancholi J.

 

Background

The prosecution alleged that Martandgouda went missing on 11.12.2011 and was later murdered pursuant to a criminal conspiracy arising out of land disputes and alleged personal animosity. The Trial Court acquitted all accused, finding the circumstantial chain incomplete. The High Court reversed the acquittal and convicted accused nos. 1–4 under ss. 302, 120-B, 201, 506 r/w s. 34 IPC.

 

Issues Framed

1. Whether the High Court was justified in reversing the Trial Court’s acquittal in a case resting on circumstantial evidence.
2. Whether the prosecution proved conspiracy, homicidal death, and involvement of the accused beyond reasonable doubt.
 

Court’s Reasoning

Issue 1: Scope of appellate interference with acquittal

• The Court reiterated settled law that an appellate court may interfere with acquittal only where the trial court’s view is perverse or wholly unreasonable.
• If two reasonable views are possible, the acquittal must stand.

Issue 2: Reliability of prosecution evidence

• Sole eye-witness (PW-5): His statement was recorded after 21 days, only after arrests; he admitted not knowing the accused personally; gave inconsistent versions under s. 161and s. 164 CrPC; failed to explain prolonged silence except alleging threats; and did not inform police despite opportunities. The Court found him unreliable and possibly planted.
• Medical evidence: PW-14 opined death may have occurred about 10 days prior to post-mortem, inconsistent with the prosecution timeline of death on 11.12.2011.
• Recovery & disclosure: Discovery of the body allegedly under s. 27 IEA was not duly proved; crucial witnesses who retrieved the body were not examined.
• Motive & conspiracy: Alleged civil disputes and personal animosity were not proved through cogent evidence; even the High Court disbelieved the conspiracy theory qua accused nos. 5 & 6, undermining the prosecution’s narrative.

The Trial Court’s appreciation was held to be a plausible view; the High Court erred in substituting it merely because another view was possible.

 

Decision 

Appeals allowed. The High Court judgment dated 28.11.2023 was set aside, and the Trial Court’s acquittal dated 30.03.2019 was restored. Appellants directed to be released forthwith if not required in any other case.

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