The High Court clarified that, while the sole testimony of the prosecutrix can suffice for conviction in rape cases if found credible and trustworthy, such testimony must inspire confidence, be corroborated by circumstances, and not be contradicted by medical evidence. Where the prosecutrix’s version lacks reliability, is contradicted by medical findings, or is undermined by delayed reporting and inconsistencies, conviction cannot rest solely on her testimony; benefit of doubt must be given to the accused. This decision reaffirms and elucidates existing Supreme Court precedent and operates as binding authority for subordinate courts in Chhattisgarh.
Summary
| Category | Data |
|---|---|
| Case Name | CRA/124/2025 of PRATAP MANJHI Vs STATE OF CHHATTISGARH, CNR CGHC010433812024 |
| Date of Registration | 16-01-2025 |
| Decision Date | 17-10-2025 |
| Disposal Nature | ALLOWED |
| Judgment Author | HON’BLE SHRI JUSTICE PARTH PRATEEM SAHU |
| Court | High Court Of Chhattisgarh |
| Bench | Single Bench: HON’BLE SHRI JUSTICE PARTH PRATEEM SAHU |
| Precedent Value | Binding on subordinate courts within Chhattisgarh |
| Overrules / Affirms | Affirms Supreme Court precedents on evidentiary standards in rape cases |
| Type of Law | Criminal Law: Indian Penal Code sections 366, 376; evidentiary principles in sexual offences |
| Questions of Law |
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| Ratio Decidendi |
The Court held that though conviction in a rape case can be based on the sole testimony of the prosecutrix if credible and trustworthy, the testimony must inspire confidence and not be contradicted by medical and surrounding evidence. In the present case, testimonies were inconsistent, no corroborative evidence existed, medical examination refuted recent sexual intercourse, and there was an unexplained delay in FIR submission. On facts, neither forcible abduction nor deceitful inducement were proven for Section 366. Accordingly, the benefit of doubt must be given to the accused. |
| Judgments Relied Upon |
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| Logic / Jurisprudence / Authorities Relied Upon by the Court |
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| Facts as Summarised by the Court |
The prosecutrix, a minor, alleged she was lured by the accused on the pretext of marriage, led to a school at night, and subjected to sexual intercourse. She later stayed at her sister’s house but did not mention the incident there. The FIR was lodged after a significant delay. Medical examination found no signs of recent sexual activity. Testimonies were inconsistent regarding critical circumstances. |
Practical Impact
| Category | Impact |
|---|---|
| Binding On | All subordinate courts in Chhattisgarh |
| Persuasive For | Other High Courts and Supreme Court (as reaffirmation of SC precedent) |
| Follows |
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What’s New / What Lawyers Should Note
- The judgment clarifies that while conviction in rape cases can be based on the sole testimony of the prosecutrix, such testimony must independently inspire confidence and not be undermined by material contradictions or adverse medical evidence.
- Medical evidence that directly contradicts the allegation (such as absence of signs of recent sexual intercourse) is a strong factor in assessing reliability.
- Delay in lodging FIR, especially where the delay is unexplained or raises suspicion of deliberation, can be fatal to prosecution if coupled with other inconsistencies.
- Defence can argue that inconsistencies in the prosecutrix’s account, lack of immediate complaint, and adverse medical evidence undermine the prosecution beyond reasonable doubt.
- Proves critical the court’s role in carefully evaluating credibility rather than mechanically accepting the prosecutrix’s statements.
Summary of Legal Reasoning
- The Court reiterated established Supreme Court law: in rape cases, the sole testimony of the prosecutrix is sufficient for conviction if it inspires confidence; however, if the testimony is inconsistent, lacks corroboration, or is contradicted by other evidence, courts must be cautious.
- Multiple precedents were cited (Aman Kumar, Krishan Kumar Malik, Babu Meena, Hem Raj, Rajoo, Sadashiv Ramrao Hadbe, Tazuddin) confirming that conviction cannot be based on unreliable prosecutrix testimony where medical and circumstantial evidence is inconsistent with the allegations.
- The Court scrutinised the prosecutrix’s cross-examination, noting delays in FIR, inconsistencies in her account, failure to inform relatives, and no injuries or signs of recent intercourse as per medical opinion.
- The judgment found the lack of corroboration—particularly the absence of injuries or confirmation of recent intercourse—fatal for the prosecution case.
- Regarding Section 366 IPC, the court held there was neither evidence of forceful abduction nor deceitful inducement, as the prosecutrix accompanied the accused voluntarily.
- The cumulative effect of delayed complaint, contradictory statements, and adverse medical and circumstantial evidence created grave doubt, entitling the accused to benefit of doubt.
Arguments by the Parties
Petitioner (Appellant):
- Trial court erred in convicting appellant under Section 376(1) IPC without thoroughly evaluating the prosecution evidence.
- The prosecutrix’s accusation is unconvincing as the medical evidence (doctor’s testimony) found no recent sexual intercourse.
- The prosecution’s case is suspicious as the prosecutrix stayed with her sister and did not disclose the incident; claim of rape is not supported.
- No case for Section 376 IPC was made out based on available evidence.
Respondent (State):
- Victim categorically stated that appellant, by misrepresenting intentions of marriage, took her to a secluded place and engaged in sexual intercourse.
- Even if intercourse was not forceful, it was procured by deceit, fulfilling the offence elements.
- Actions of the appellant, including leaving the victim after his intention not to marry became clear, establish guilt under Sections 366 and 376(1) IPC.
Factual Background
The prosecutrix, a minor girl, alleged that the accused lured her on the pretext of marriage at night, took her to a nearby school, and had sexual intercourse with her, then later dropped her at her sister’s house in a different village. She did not immediately inform her sister or any relative about the incident. The FIR was filed nearly six days after the incident, allegedly due to family discussions and after marriage with the accused did not materialize. Medical examination revealed no signs of recent sexual activity or injury.
Statutory Analysis
- Section 376 IPC (Rape): The court restated that conviction could rest on the sole testimony of the prosecutrix only if it is wholly credible and trustworthy. Where there are serious doubts due to medical evidence and circumstances, corroboration is required.
- Section 366 IPC (Kidnapping, abducting or inducing woman to compel marriage, etc.): The court explained that the section requires evidence of forceful compulsion or deceitful inducement to establish the offence. The facts did not prove either element; the prosecutrix accompanied the accused voluntarily.
- Deliberation on requirements for timely FIR lodging and the significance of unexplained delay as an indicator of possible embellishment or false implication.
Dissenting / Concurring Opinion Summary
No dissenting or separate concurring opinion is recorded in the judgment.
Procedural Innovations
No explicit procedural innovations detailed in the judgment.
Alert Indicators
- ✔ Precedent Followed – The decision follows and reaffirms established Supreme Court precedent regarding evidentiary standards in rape prosecutions.