C. Mangesh & Ors etc v. State of Karnataka (2010)
Quick Summary
This case explains how courts should weigh evidence before convicting. The events began with a labour dispute at BPL Engineering in Bengaluru. A bus with employees was attacked and set on fire. Two young women later died from burn injuries. Many were tried; some were acquitted; some were convicted. On appeal, the Supreme Court closely examined the value of the FIR, the dying declarations, and the standards for reversing acquittal.
c-mangesh-ors-etc-v-state-of-karnataka-2010
Issues
- Are the appellants guilty of offences under Sections 302, 307, 435, 427, 143, 148 read with 149 IPC?
- How should courts treat the FIR and dying declarations while deciding guilt?
- When can an appellate court overturn an acquittal under Section 378 CrPC?
Rules (Court’s Observations)
- FIR is not substantive evidence. It may corroborate or contradict its maker; it cannot by itself prove guilt. (Baldev Singh v. State of Punjab, 1990)
- Dying declarations: Must be credible. In this case, concerns arose because:
- Statements under Section 161 CrPC do not require signatures; Section 162 prohibits it.
- Declarations were not in Q&A format.
- No Magistrate recorded the declarations despite availability in a metro city.
- Reversing acquittal (Section 378 CrPC): Keep presumption of innocence intact; if two views are possible, prefer the one favouring the accused; respect trial judge’s advantage of seeing witnesses; give reasonable, rational benefit of doubt.
Facts (Timeline)
Optional timeline image
BPL Engineering in Bengaluru used many temporary workers, mainly women. Workers formed a union seeking regular jobs.
Despite legal hurdles by management, the union was registered; protests and hunger strikes followed.
Legal steps included police protection requests and civil injunctions against demonstrations within 100 meters of the units.
A bus with “loyal” employees was attacked; stones were thrown; kerosene was used; the bus was set on fire. Many were injured.
Two passengers, Sinija and Nagarathna, later died from burn injuries. Police seized evidence, examined witnesses, and arrested accused persons.
49 were charge-sheeted for murder, attempt to murder, rioting, arson, and related offences. A long trial followed.
Trial court convicted A1, A2, A15, A25, A32, A33, A46 and acquitted 42 others. State sought harsher punishment and challenged acquittals.
High Court convicted four more (A4, A8, A16, A34). Appeals reached the Supreme Court.
Arguments
Appellants (Accused)
- Dying declarations lack reliability and proper recording safeguards.
- FIR and other statements cannot replace solid, substantive proof.
- Acquittals should not be reversed without strong reasons under Section 378 CrPC.
State of Karnataka
- Large-scale violence is proved by eyewitnesses, documents, and material objects.
- Dying declarations reflect immediate truth spoken in extremis.
- Convictions of key accused should be upheld; some acquittals deserved reversal.
Judgment
Mixed OutcomeThe Supreme Court gave a balanced ruling:
- Convictions confirmed: A1, A2, A15, A32, A33 — based on consistent, credible evidence.
- Acquittals ordered: A25, A46 — released if not wanted in other cases.
- Appeals allowed (set aside High Court conviction): A4, A8, A16, A34 — released unless required elsewhere, due to doubts over dying declarations.
Applications under Sections 91 and 233 CrPC (to summon more documents/witnesses) were rightly rejected by the trial court; no prejudice was caused.
Ratio Decidendi
Courts must not convict unless evidence is reliable and consistent. FIRs only corroborate; they do not, by themselves, prove guilt. Dying declarations need careful checks of recording method and credibility. When reviewing acquittals, the presumption of innocence and reasonable doubt remain central.
Why It Matters
- Clarifies the limited role of FIR in proof.
- Sets credibility checks for dying declarations.
- Reaffirms high threshold for overturning acquittals.
Key Takeaways
- FIR ≠ substantive evidence; it only supports or contradicts the maker.
- Dying declarations must be recorded and assessed with care; doubt helps the accused.
- Appellate courts respect the trial judge’s view of witnesses and the presumption of innocence.
- Consistent, multi-source proof can sustain convictions in group-violence cases.
Mnemonic + 3-Step Hook
Mnemonic: “FIR Can’t Convict; Declarations Demand Doubt.”
- FIR Can’t Convict = FIR is not substantive.
- Declarations Demand Doubt = dying declarations need strict checks.
3-Step Hook:
- Check what the law allows (FIR, 161/162 CrPC).
- Test reliability (who, how, when recorded).
- Decide with doubt in mind for the accused.
IRAC Outline
| Issue | Rule | Application | Conclusion |
|---|---|---|---|
| Are appellants guilty under IPC 302/307/435/427 with 143/148/149? | FIR not substantive; dying declarations must be credible; Section 378 standards for acquittal reversal. | Declarations had recording gaps; some evidence consistent against key accused; others benefited from doubt. | Five convictions affirmed; four High Court convictions set aside; two acquittals restored. |
Glossary
- FIR
- First Information Report; starts police investigation; not proof by itself.
- Dying Declaration
- Statement made by a person about the cause of their death or circumstances of the transaction.
- Section 161/162 CrPC
- Police record statements (no signatures). Such statements are limited in evidentiary use.
- Section 378 CrPC
- Appeals against acquittal; strict standards protect the presumption of innocence.
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