The Supreme Court has set aside the Karnataka High Court’s decision that convicted three men in a 2011 murder case from Gadag district, holding that the prosecution failed to establish a complete and reliable chain of evidence. Restoring the trial court’s acquittal, the apex court ruled that suspicion, however strong, cannot replace proof in criminal trials.
Background of the Case
The case relates to the disappearance and alleged murder of one Martandgouda, a resident of Hulkoti village in Gadag district. He went missing on December 11, 2011. Five days later, his son lodged a missing complaint, which later turned into a murder case based on suspicion arising from a long-standing land dispute within the family.
The prosecution alleged that Martandgouda was abducted, murdered, and his body disposed of in a canal following a criminal conspiracy involving multiple accused. Charges were framed under Sections 302 (murder), 120-B (criminal conspiracy), 201 (causing disappearance of evidence), and 506 (criminal intimidation) of the IPC.
In 2019, the trial court acquitted all the accused, holding that the prosecution failed to prove its case beyond reasonable doubt. However, in November 2023, the Karnataka High Court reversed the acquittal and convicted four of the accused, leading to the present appeal before the Supreme Court.
Key Evidence and Prosecution Claims
The prosecution relied mainly on:
- A so-called eyewitness (PW-5), who claimed to have seen the deceased with the accused on the day of disappearance
- Alleged recovery of the body based on disclosure statements
- Motive arising from property disputes and alleged illicit relationships
- Medical evidence suggesting homicidal death
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It was argued that the accused conspired to eliminate the deceased due to land disputes and personal enmity, and later disposed of the body in a canal.
Court’s Observations
The Supreme Court found serious flaws in the prosecution case. It noted that:
- The star witness, PW-5, came forward 21 days after the incident, raising serious doubts about credibility.
- His testimony contained contradictions and omissions, and he admitted he did not know the accused personally.
- The alleged recovery of the body was not properly proved, as crucial witnesses who retrieved the body were never examined.
- Medical evidence did not conclusively match the prosecution’s timeline of death.
- The alleged conspiracy was based largely on suspicion and assumptions rather than concrete proof.
“The prosecution failed to establish an unbroken chain of circumstances pointing only towards the guilt of the accused,” the bench observed. It added that mere suspicion or strained relations cannot take the place of legal proof.
The Court also reiterated settled law that an appellate court should not interfere with an acquittal unless the trial court’s view is perverse or wholly unreasonable.
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Supreme Court’s Decision
Allowing the appeals, the Supreme Court set aside the High Court’s judgment and restored the trial court’s acquittal.
“The view taken by the trial court was a plausible one based on the evidence on record. The High Court erred in reversing the acquittal merely because another view was possible,” the bench held.
The Court ordered the immediate release of the appellants, unless required in any other case.
Case Title: Tulasareddi @ Mudakappa & Ors. v. State of Karnataka
Case No.: Criminal Appeal Nos. 2120–2121 & 2542–2543 of 2024
Decision Date: 16 January 2026
