The High Court of Chhattisgarh sets aside a conviction under Section 354 IPC, reaffirming that courts must acquit where the prosecution fails to prove the case beyond reasonable doubt due to material inconsistencies. The judgment upholds the Supreme Court’s precedent on extending the benefit of doubt and serves as binding authority for subordinate courts in Chhattisgarh.
Summary
| Category | Data |
|---|---|
| Case Name | CRR/606/2016 of Jai Kumar Vs State Of Chhattisgarh |
| CNR | CGHC010013092016 |
| Date of Registration | 30-06-2016 |
| Decision Date | 16-10-2025 |
| Disposal Nature | ALLOWED |
| Judgment Author | Hon’ble Shri Justice Radhakishan Agrawal |
| Court | High Court of Chhattisgarh at Bilaspur |
| Precedent Value | Binding on subordinate courts in Chhattisgarh |
| Overrules / Affirms |
|
| Type of Law | Criminal Law |
| Questions of Law | Whether a conviction under Section 354 IPC can be sustained in the face of material inconsistencies and lack of corroboration? |
| Ratio Decidendi |
The Court held that in criminal trials, if the prosecution evidence suffers from material inconsistencies and does not corroborate key facts, and the victim is unavailable, the benefit of doubt must be given to the accused. Relying on the Supreme Court’s decision in Irfan @ Naka v. State of Uttar Pradesh (2023), the Court underscored that it is the prosecution’s duty to prove guilt beyond reasonable doubt. Where there is a failure to do so, conviction is unsustainable and acquittal must follow. The evidence in this case, including contradictory witness statements and lack of medical examination, was found too inconsistent to support conviction. The trial and appellate court judgments were consequently set aside. |
| Judgments Relied Upon | Irfan @ Naka v. State of Uttar Pradesh, 2023 SCC OnLine SC 1060 |
| Logic / Jurisprudence / Authorities Relied Upon by the Court | Principle of “benefit of doubt,” burden of proof beyond reasonable doubt in criminal cases |
| Facts as Summarised by the Court |
Allegation of outraging modesty by accused while complainant was leaving home. FIR registered under Section 354 IPC. Prosecution based on testimonies of family members and neighbors; the victim (complainant) passed away before trial. Contradictory witness statements; no medical examination conducted. |
Practical Impact
| Category | Impact |
|---|---|
| Binding On | All subordinate courts in Chhattisgarh |
| Persuasive For | Other High Courts |
| Follows | Irfan @ Naka v. State of Uttar Pradesh, 2023 SCC OnLine SC 1060 |
What’s New / What Lawyers Should Note
- Reiterates that in cases of material inconsistencies among prosecution witnesses, and absence of corroborative evidence (such as medical examination), the accused must be given the benefit of doubt.
- Sets aside convictions even at revision stage where the prosecution evidence is not cogent and clinching.
- Judges and lawyers should strictly examine consistency between FIR, witness statements, and oral depositions in sexual offence cases.
- Reinforces reliance on Supreme Court precedent regarding burden of proof and standard of “beyond reasonable doubt.”
- Provides a clear precedent for defense in revision/appeal to challenge convictions resting on contradictory evidence.
Summary of Legal Reasoning
- The Court begins by summarizing the rival contentions concerning contradictory statements and lack of corroboration.
- A meticulous analysis of witness depositions revealed material inconsistencies, particularly regarding the presence and actions of key eyewitnesses and the specifics about the alleged offence.
- Attention is drawn to the absence of medical examination of the victim, further undermining the prosecution’s case.
- While examining the statements, the Court highlighted missing details in both FIR and witness statements under Section 161 CrPC.
- The High Court specifically relies on the Supreme Court decision in Irfan @ Naka v. State of Uttar Pradesh (2023), which reinforces that the benefit of doubt must always go to the accused if the prosecution falls short of proving its case beyond reasonable doubt.
- On this legal foundation and factual analysis, the Court finds the conviction unsustainable, sets aside the lower court orders, and acquits the accused.
Arguments by the Parties
Petitioner (Applicant):
- The conviction is unjustified due to improper appreciation of evidence by the lower courts.
- There are material contradictions and omissions in prosecution witnesses’ statements.
- Witness depositions do not corroborate with each other or with the FIR.
- There is no cogent evidence to prove that the applicant committed the offence.
- Sought acquittal on the basis of benefit of doubt.
Respondent (State):
- Supported the judgments of the trial and appellate courts.
- Asserted that the conviction and sentence were justified and free from illegality or infirmity.
Factual Background
The prosecution alleged that on 17.05.2013, at about 5:00 am, the accused attempted to outrage the complainant’s modesty while she was leaving her house. When the complainant raised an alarm, a neighbor arrived and the accused allegedly fled. A police report was filed, resulting in FIR under Section 354 IPC. During the investigation, statements of witnesses were recorded and some physical evidence was seized. The victim (complainant) passed away before she could be examined in court. Contradictory accounts emerged in the testimonies of neighbors and family members regarding the precise circumstances and identification of the accused.
Statutory Analysis
- Sections 397 and 401 of CrPC: Jurisdiction invoked for criminal revision challenging the conviction and appellate affirmation.
- Section 354 IPC: The core penal provision concerning assault or criminal force with intent to outrage a woman’s modesty.
- Discussion referenced procedural sections regarding examination of witnesses (Section 161 CrPC) and requirements in criminal investigations such as medical examination of the complainant.
- Court referenced Section 481 of BNSS regarding the continuance of bail bonds after acquittal.
Procedural Innovations
- Court directed that the applicant’s bail bonds remain operative for six months post-acquittal in accordance with Section 481 of BNSS.
Alert Indicators
- Precedent Followed – Supreme Court law reaffirmed regarding benefit of doubt and standard of proof.