HEADNOTE
State (NCT of Delhi) v. Sanjay @ Anit @ Nita Singh
Court: High Court of Delhi
Bench: Justice Neena Bansal Krishna
Date of Judgment: 15 December 2025
Citation: CRL.A. 1544/2025 (CRL.L.P. 720/2017)
Laws / Sections Involved: Sections 279, 338, 304A IPC; Sections 32/192 and 146/196 Motor Vehicles Act, 1988; Section 378(1)(b) CrPC
Keywords: Rash and negligent driving, appeal against acquittal, benefit of doubt, res ipsa loquitur, road accident deaths, Section 304A IPC
Summary:
The Delhi High Court dismissed the State’s appeal against acquittal of an accused charged with causing death and injuries in a triple-motorcycle collision, holding that the prosecution failed to prove rashness or negligence beyond reasonable doubt. While the identity of the accused as the rider of the offending motorcycle was undisputed, the Court found that the sole eyewitness–injured complainant had become unconscious immediately after impact and could not depose about the manner of driving. The FIR narrative alleging high speed and negligence was found unreliable, having been written by the investigating officer and merely signed by the complainant. The site plan and other circumstantial evidence also failed to explain how the accident occurred. Reiterating that mere occurrence of an accident or resulting fatalities cannot automatically establish criminal negligence, the Court upheld the trial court’s grant of benefit of doubt and declined to interfere with the acquittal.
Court’s decision
The Delhi High Court dismissed the criminal appeal filed by the State under Section 378(1)(b) CrPC and affirmed the judgment of acquittal dated 29 April 2017 passed by the Metropolitan Magistrate. The Court held that the trial court had correctly appreciated the evidence on record and that no perversity or misreading of evidence was demonstrated. It ruled that in the absence of reliable evidence explaining the manner of the accident and establishing rash or negligent driving, interference with an acquittal was unwarranted. All pending applications were disposed of accordingly.
Facts
The prosecution case arose out of an accident dated 18 November 2011 at about 6:25 PM near Jhatikra Mod, Najafgarh. The accused was alleged to have been riding a motorcycle without valid insurance or registration and to have collided with two other motorcycles, resulting in injuries to Rajesh Kumar and the death of two young men, Ravi and Guddu Negi. An FIR was registered under Sections 279, 338 and 304A IPC along with offences under the Motor Vehicles Act.
During trial, the prosecution examined 15 witnesses, including the injured Rajesh (PW-1), relatives of the deceased, police officials, doctors who proved the MLCs and post-mortem reports, and mechanical inspectors. The accused admitted that he was driving the motorcycle at the relevant time but denied rash or negligent driving, asserting that the accident occurred between the other two motorcycles.
Issues
The central issue before the High Court was whether the prosecution had proved beyond reasonable doubt that the accused was driving the offending motorcycle in a rash or negligent manner so as to attract criminal liability under Sections 279, 338 and 304A IPC. A related issue was whether the trial court erred in granting the benefit of doubt and acquitting the accused, warranting appellate interference in an appeal against acquittal.
Appellant’s arguments (State)
The State argued that the trial court had failed to appreciate the testimony of the injured eyewitness, PW-1 Rajesh, who had identified the accused and described the offending motorcycle as being driven at high speed in a rash and negligent manner. It was contended that minor contradictions in his testimony could not demolish the prosecution case. The State further invoked the doctrine of res ipsa loquitur, arguing that the very nature of the accident, involving three motorcycles and resulting in two deaths, was sufficient to infer negligence. According to the State, the acquittal was based on conjectures and deserved to be set aside.
Respondent’s arguments
The accused supported the judgment of acquittal, contending that PW-1 became unconscious immediately after the impact and was therefore incapable of explaining how the accident occurred. It was argued that the FIR version alleging rashness and high speed was unreliable, as PW-1 had admitted that the complaint was written by the investigating officer and merely signed by him without being read. The respondent submitted that the prosecution had failed to explain how the third motorcycle was involved in the accident, and that the site plan did not support the prosecution’s theory.
Analysis of the law
The High Court analysed the settled principles governing offences under Sections 279 and 304A IPC, reiterating that criminal rashness or negligence must be proved by clear and cogent evidence. The Court emphasised that negligence cannot be presumed merely because an accident has occurred or because the consequences were grave. In criminal law, the standard of proof remains beyond reasonable doubt, and any ambiguity in the prosecution case must enure to the benefit of the accused. The Court also noted the limited scope of interference in an appeal against acquittal, particularly where the trial court’s view is a plausible one.
Precedent analysis
While the Court did not overturn any specific precedent, its reasoning is consistent with long-standing Supreme Court jurisprudence holding that res ipsa loquitur has limited application in criminal trials and cannot replace proof of essential ingredients of the offence. The judgment also aligns with authority that appellate courts should be slow to interfere with acquittals unless the findings are manifestly illegal or perverse.
Court’s reasoning
Justice Neena Bansal Krishna observed that the testimony of PW-1 only established that the accused’s motorcycle came from the opposite direction and collided with his motorcycle. Crucially, PW-1 admitted that he became unconscious immediately after the impact and regained consciousness only in hospital, and that he remembered nothing about what transpired thereafter. The Court found that the FIR statement alleging rash and negligent driving could not be relied upon, as PW-1 denied having dictated its contents.
The Court further noted that the site plan did not explain the manner of collision or how the third motorcycle was hit, and that no independent evidence was led to clarify this aspect. In such circumstances, the Court held that the prosecution failed to establish rashness or negligence, and the trial court was justified in granting the benefit of doubt.
Conclusion
The Delhi High Court concluded that the prosecution case suffered from serious evidentiary gaps and failed to prove the essential ingredient of rash or negligent driving. Holding that the trial court’s acquittal was based on a reasonable appreciation of evidence, the Court dismissed the State’s appeal and affirmed the acquittal of the accused.
Implications
This judgment reinforces the high threshold required to sustain criminal convictions for road accidents under Section 304A IPC. It clarifies that tragic consequences alone cannot substitute for proof of culpable negligence and that courts must carefully scrutinise eyewitness testimony, FIRs, and site plans before attributing criminal liability. The ruling also reiterates judicial restraint in interfering with acquittals, thereby strengthening the presumption of innocence.
CASE LAW REFERENCES
• State of Karnataka v. Satish – Speed alone not decisive of rashness or negligence
• Keshavlal v. State of Maharashtra – Criminal negligence must be proved beyond reasonable doubt
• Chandrappa v. State of Karnataka – Limited scope of appeal against acquittal
FAQs
Q1. Can rashness be presumed merely because an accident caused death?
No. Courts require clear evidence of rash or negligent driving; mere occurrence of an accident is insufficient.
Q2. Is the doctrine of res ipsa loquitur enough to convict in criminal cases?
No. Its application is limited and cannot replace proof beyond reasonable doubt.
Q3. When will High Courts interfere with an acquittal?
Only where the trial court’s findings are perverse, illegal, or wholly unreasonable.