DATE: 20/02/2025
BENCH: Justice Surya Kant and Justice NK Singh
FACTS:
The case arises from an incident on 13.08.2007, when the prosecutrix (PW-10) lodged an FIR through her father under Sections 452 and 376 of the IPC at Police Station Sadar Hamirpur. According to the complaint, while her parents (PW-8 and PW-9) were away purchasing medicines, the accused approached their house asking for a matchbox. Finding the prosecutrix alone, the accused allegedly forced her into a room and committed sexual intercourse with her. Upon her parents' return, the prosecutrix informed them about the incident, leading to the FIR being filed.
The prosecutrix was examined by Dr. Sunita Galodha (PW-7) at Regional Hospital, Hamirpur, where she was found to be of unsound mind and uncooperative during the examination. Consequently, she was referred to RPMC Hospital, Tanda, for further medical evaluation, but her father refused to allow the examination. Despite this, the police had collected a vaginal swab for forensic analysis. Based on the evidence, including testimonies from 14 witnesses and the accused’s statement under Section 313 CrPC, the Trial Court convicted the accused under Sections 452 and 376 IPC, sentencing him to 10 years of rigorous imprisonment along with a fine which was later overruled by the High Court and acquitted the accused.
ISSUES:
The main issue in this case is whether the acquittal made by the High Court was on the basis of the clear evidence.
JUDGEMENT WITH REASONING:
The Supreme Court dismissed the appeal against the High Court’s judgment, which had acquitted the accused of charges under Sections 376 and 452 of the IPC. The Court upheld the High Court's decision, affirming that the accused deserved the benefit of the doubt.
The Court noted significant inconsistencies and gaps in the prosecution's case. The father of the prosecutrix failed to provide a reasonable explanation for the delay in lodging the FIR, which weakened the credibility of the complaint. The testimony of Nirmala Devi (PW-1) confirmed that the matter was reported three days after the alleged incident, further raising doubts. Additionally, the prosecutrix and her family’s lack of cooperation during the medical examination, combined with the absence of injuries, semen, or blood evidence, substantially undermined the allegations.
Moreover, the prosecutrix’s clear understanding during cross-examination confirmed that she was mentally sound, contradicting earlier claims. The Court also acknowledged that the prosecutrix was 19 years old at the time of the incident, reinforcing her ability to comprehend and communicate the events. Considering these factors, the Court found no error or misjudgment in the High Court's thorough analysis and concluded that interference in the acquittal was unwarranted.
ANALYSIS:
The Supreme Court's decision reflects a strong emphasis on the principles of criminal jurisprudence, particularly the requirement for the prosecution to establish guilt beyond a reasonable doubt. The Court carefully scrutinized the inconsistencies in the prosecution's narrative, highlighting the unexplained delay in lodging the FIR as a crucial factor that weakened the case. Delayed reporting in criminal cases, especially those involving serious allegations like rape, often raises concerns about the authenticity of the claims unless justified with reasonable explanations. In this instance, the father's failure to provide a credible reason for the delay, coupled with Nirmala Devi's (PW-1) testimony indicating a three-day gap, created doubts regarding the reliability of the allegations. Furthermore, the prosecutrix’s non-cooperation during her medical examination, combined with the absence of physical evidence such as injuries, semen, or blood, significantly undermined the prosecution's case. These gaps, the Court concluded, made it difficult to sustain a conviction based solely on oral testimony.
The Supreme Court’s reliance on established legal principles, such as the benefit of the doubt and non-interference with well-reasoned acquittals, underscores its commitment to safeguarding individual rights in the face of unreliable evidence. The Court noted that the High Court had conducted a detailed assessment of the facts and found no compelling reason to overturn its findings. The prosecutrix's demonstrated mental competence during cross-examination, coupled with her age of 19 years at the time of the incident, further supported the conclusion that she was capable of understanding and recounting the events. The judgment highlights the Court's careful balancing of the victim’s allegations against the accused’s right to a fair trial, ultimately emphasizing that a conviction must rest on consistent, credible, and corroborated evidence.
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