01 Read
What happened
The Supreme Court in Ravi Kumar Singh Malhotra v. State of Madhya Pradesh (2026 INSC 899) restored a trial court acquittal that the High Court had reversed. The Court held that the High Court exceeded its limited appellate jurisdiction over acquittals by substituting its own view for the trial court's reasoned doubts about a child witness's testimony. Mere suspicion arising from the accused's explanation, the Court ruled, cannot substitute for cogent and reliable proof required to sustain a conviction.
02 Understand
Why it matters
This judgment reinforces two intersecting principles in criminal procedure that CLAT PG examiners repeatedly test.
First, the standard for reversing an acquittal in appeal is markedly higher than for reversing a conviction. Under Section 386 CrPC (Section 432 BNSS), an appellate court can reverse an acquittal, but the Supreme Court has consistently held — from Chandrappa v. State of Karnataka (2007) to this ruling — that this power must be exercised only when the trial court's view is 'perverse,' 'manifestly erroneous,' or 'wholly unreasonable.' A mere difference of opinion is insufficient. The High Court must find that no reasonable court could have arrived at the acquittal on the evidence presented.
Second, the judgment clarifies the evidentiary standard in criminal trials. The prosecution must prove guilt beyond reasonable doubt through cogent, credible, and reliable evidence. Suspicion — even strong suspicion — cannot fill the gap left by insufficient proof. The accused's explanation under Section 313 CrPC (Section 351 BNSS) may raise inference, but an adverse inference from a weak explanation cannot substitute for the prosecution's primary burden.
The child witness dimension is also significant. Courts must assess a child witness's competency and credibility with care, but a trial court's reasoned doubts about such testimony are entitled to deference on appeal, not summary rejection.
This case sits at the intersection of appellate jurisdiction, burden of proof, and child witness credibility — three perennially tested themes in CLAT PG criminal procedure passages.
First, the standard for reversing an acquittal in appeal is markedly higher than for reversing a conviction. Under Section 386 CrPC (Section 432 BNSS), an appellate court can reverse an acquittal, but the Supreme Court has consistently held — from Chandrappa v. State of Karnataka (2007) to this ruling — that this power must be exercised only when the trial court's view is 'perverse,' 'manifestly erroneous,' or 'wholly unreasonable.' A mere difference of opinion is insufficient. The High Court must find that no reasonable court could have arrived at the acquittal on the evidence presented.
Second, the judgment clarifies the evidentiary standard in criminal trials. The prosecution must prove guilt beyond reasonable doubt through cogent, credible, and reliable evidence. Suspicion — even strong suspicion — cannot fill the gap left by insufficient proof. The accused's explanation under Section 313 CrPC (Section 351 BNSS) may raise inference, but an adverse inference from a weak explanation cannot substitute for the prosecution's primary burden.
The child witness dimension is also significant. Courts must assess a child witness's competency and credibility with care, but a trial court's reasoned doubts about such testimony are entitled to deference on appeal, not summary rejection.
This case sits at the intersection of appellate jurisdiction, burden of proof, and child witness credibility — three perennially tested themes in CLAT PG criminal procedure passages.
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