When Two Cases Arise from the Same Incident, They Must Be Tried Together to Avoid Conflicting Judgments: Karnataka High Court

In a significant ruling, the Karnataka High Court on March 4, 2025, set aside an acquittal in a criminal case after finding that the Sessions Court failed to conduct a joint trial with a counter case arising from the same incident. "The Sessions Court ought to have directed the Magistrate to commit the counter case for a joint trial. The failure to do so vitiates the proceedings," observed a division bench comprising Justice Sreenivas Harish Kumar and Justice K.S. Hemalekha. The case involved allegations of assault linked to a land dispute in Janupanahalli village, Tumakuru.

The prosecution alleged that on August 25, 2012, at 6:30 AM, Lakshmidevi (PW1) and her father (PW5) were ploughing their land when the accused claimed ownership over the property and launched an attack. In the altercation, both PW1 and PW2 sustained injuries, leading to the registration of Crime No. 273/2012 against the accused under Sections 143, 147, 148, 323, 324, 341, 354, 307, 447, and 504 read with 149 of the IPC.

However, in a parallel development, the accused lodged a counter-complaint (Crime No. 274/2012) against PW5 and others, alleging that they were the actual aggressors. The Sessions Court, Tumakuru, acquitted the accused on February 4, 2017, in S.C. No. 145/2014, without considering the existence of the counter case, which was still pending before the Magistrate.

Both Lakshmidevi and the State of Karnataka challenged the acquittal, arguing that the Sessions Court’s failure to try both cases together deprived the trial of fairness and completeness.

Emphasizing the necessity of joint trials in cases with cross-complaints, the Karnataka High Court ruled that the Sessions Court’s failure to consolidate the cases undermined the legal process. The bench relied on the judgment in State of Karnataka v. Hosakeri Ningappa (ILR 2012 KAR 509) and reiterated, "Whenever there are two cases emanating from the same incident, it is necessary that they must be tried in the same court to avoid conflicting judgments."

The Court noted that the purpose of a joint trial is to determine the real aggressor and ensure a just outcome, which was not possible when one side of the story was adjudicated while the counter case remained pending before a lower court.

The prosecution conceded that the counter-complaint was never committed to the Sessions Court, and this failure resulted in a trial that was fundamentally flawed from a procedural standpoint. The High Court firmly observed, "A Sessions Court cannot proceed with one case while the counter-case lingers before a Magistrate. Such an approach renders the entire process defective."

After considering the procedural lapse and the impact on the fairness of the trial, the High Court ruled that the acquittal must be set aside and the case remanded for a joint trial. The Court directed:

•    "The judgment of acquittal dated 04.02.2017 in S.C. No. 145/2014 is set aside. The Sessions Court, Tumakuru, shall direct the Magistrate to transmit the counter-case records for a joint trial."
•    "It is not necessary to conduct a de novo trial. The evidence already recorded shall be retained, and additional evidence shall be taken in the counter-case."
•    "The accused persons in both cases shall appear before the Sessions Court, Tumakuru, on April 9, 2025, by which time the court shall secure the counter-case records."
•    "This approach will ensure that both cases are tried together and justice is done in an impartial manner."

The ruling by the Karnataka High Court highlights the fundamental principle that criminal cases arising from the same incident must be tried together to prevent inconsistent outcomes. By remanding the case for a joint trial, the Court has reinforced the importance of procedural integrity and the need for courts to consider the entirety of a dispute before rendering a decision. The judgment ensures that both sides of the conflict are adjudicated together, allowing the court to determine the actual aggressor and deliver a fair verdict.
Date of Decision: 04 March 2025