A reliable prosecutrix’s uncorroborated testimony can sustain a rape conviction.

On 8 April 2003, the prosecutrix alleged that while she was working in her Bari at about 12:00 noon, the appellant came there, threatened her with a knife, forcibly overpowered her, and raped her twice.

She thereafter disclosed the incident to her bhabhi, and the matter was subsequently reported to the villagers and the police.

The appellant was allegedly assaulted by villagers and handed over to the police.

Karra P.S. Case No. 21 of 2003 was registered under Section 376 of the Indian Penal Code (IPC).

After investigation, a charge-sheet was filed and the appellant was tried in Sessions Trial No. 573 of 2003.

The prosecution examined seven witnesses and relied principally upon the prosecutrix’s testimony and medical evidence.

The trial court convicted the appellant under Section 376 IPC and sentenced him to seven years’ rigorous imprisonment on 28–29 September 2004.

Whether the conviction of the appellant under Section 376 IPC could be sustained on the testimony of the prosecutrix, notwithstanding the alleged contradiction regarding the knife and the absence of independent corroboration?

Whether the medical and other evidence sufficiently corroborated the prosecutrix’s account so as to sustain the conviction and sentence?

The Court applied Section 376 IPC, which criminalises rape.

It reiterated the settled principle that the conviction of an accused may be based on the solitary testimony of the prosecutrix, provided her evidence is reliable, trustworthy, unblemished, and of sterling quality; independent corroboration is not an indispensable legal requirement.

Relying on Krishan Kumar Malik v. State of Haryana, (2011) 7 SCC 130, the Court held that the prosecutrix’s testimony can by itself sustain a conviction when it inspires confidence.

The Court also observed that medical evidence is corroborative and cannot replace substantive ocular evidence.

The Court found the prosecutrix’s account consistent on the material fact that the appellant forcibly had sexual intercourse with her while she was working in her Bari during the daytime.

Her testimony was materially corroborated by the medical examination, which recorded the presence of spermatozoa, signs of recent intercourse, a fresh hymenal tear, lacerated injury, swelling, and congestion in the vaginal region.

The medical evidence also assessed her age at approximately 16–18 years, though the conviction was founded on Section 376 IPC.

The Court treated the statement that she had not actually seen the knife as insufficient to discredit her allegation of rape, particularly because the central allegation of forcible sexual assault remained intact.

The defence allegation of previous enmity was unsupported by concrete evidence, and the non-production of seized materials or other corroborative evidence did not create reasonable doubt.

Applying the rule that reliable testimony of the prosecutrix requires no independent corroboration, the Court held that the prosecution had proved the charge beyond reasonable doubt.

As the appellant was on bail, his bail bond was cancelled, and he was directed to surrender before the trial court within two months to undergo the remaining sentence; failing surrender, the trial court was directed to take coercive steps to secure his custody.