Sahabrao Bobade v. State of Maharashtra

The Supreme Court upheld the High Court’s reversal of acquittal. An appellate court may re-read all evidence and reach its own view, but it must give very convincing reasons. The Court warned: only reasonable doubts help the accused; imaginary doubts do not. A single credible eyewitness can sustain conviction, especially with support like a dying declaration and discovery of weapons.

1. Was the High Court justified in reversing the Sessions Court’s acquittal?
2. Does overuse of the “benefit of doubt” rule harm justice and public trust?
3. Did the prosecution prove guilt beyond reasonable doubt on the record?

• Appellate power: Full power to reassess evidence; use with care; acquittal strengthens the presumption of innocence; reversal needs comprehensive reasons.
• Benefit of doubt: Only reasonable doubts count. Exaggerated or speculative doubts cannot defeat credible proof.
• Quality over quantity: One clear, cogent, credible eyewitness can be enough; corroboration is wise but not always necessary.
• Motive: Helps probability; not essential when evidence firmly proves guilt.

The Supreme Court dismissed the appeal and kept the High Court conviction. It held that the High Court used its appellate power properly, gave solid reasons, and relied on credible evidence. Minor inconsistencies did not shake the core story. The oral dying declaration was natural and accepted.

• Appellate courts may fully re-appraise evidence in appeals against acquittal, but must act with caution and record convincing reasons.
• Only reasonable doubts aid the accused; exaggerated doubts harm justice.
• A single credible eyewitness can ground conviction; corroboration, if present, strengthens it.
• Motive is helpful, not essential, when other proof is firm.

This case guides courts on reversing acquittals and sets a realistic view of “benefit of doubt.” It reassures victims and the public that strong, credible evidence will not be defeated by fanciful doubts.

• Full re-appraisal allowed on appeal against acquittal; give clear reasons.
• Reasonable doubt ≠ every doubt; avoid speculative doubts.
• Single credible witness + supporting facts (dying declaration, recoveries) can prove guilt.

Mnemonic: “Re-read, Reasons, Reasonable doubt”

1. Re-read all evidence (appellate power).
2. Reasons must be strong to reverse acquittal.
3. Reasonable doubt only—no fanciful doubts.

Benefit of Doubt

A safeguard for the accused, but only for doubts that are reasonable and real.

Dying Declaration

Statement by a person about the cause of death or circumstances of the transaction, made before death.

Corroboration

Additional support to a key witness or fact; helpful but not always mandatory.