Conviction cannot rest on prosecutrix’s testimony where material contradictions and medical evidence undermine its credibility.

On 7 July 2007, the prosecutrix alleged that while returning from a village fair, the appellant forcibly took her on a bicycle to a ditch near Murligaraha Pahari and committed rape after gagging her mouth.

Villagers subsequently found and apprehended the appellant and brought him to the village; the prosecutrix lodged the written report at the police station the following morning.

An FIR was registered under Section 376 IPC, followed by investigation and submission of a charge-sheet.

The Trial Court convicted the appellant under Section 376 IPC and sentenced him to seven years’ rigorous imprisonment and a fine of ₹5,000.

In appeal, the appellant challenged the alleged delay in lodging the FIR, material contradictions in the prosecutrix’s account, lack of independent corroboration, the medical evidence, and the possibility of false implication arising from a prior dispute concerning a water-pump machine.

Whether the conviction under Section 376 IPC could be sustained solely on the testimony of the prosecutrix in light of the inconsistencies and omissions in her various statements.

Whether the medical evidence and surrounding circumstances sufficiently corroborated the allegation of rape.

Whether the alleged delay in lodging the FIR and the defence plea of prior enmity created reasonable doubt regarding the prosecution case.

The Court applied Section 376 of the Indian Penal Code, under which rape must be proved beyond reasonable doubt.

It reiterated that the testimony of a prosecutrix in a rape case can, in principle, be sufficient for conviction without independent corroboration if, upon careful scrutiny, it is reliable and inspires confidence.

However, where the prosecutrix does not satisfy the standard of a “sterling witness” and her testimony contains material contradictions, conviction solely on that testimony is unsafe.

The Court relied on Santosh Prasad @ Santosh Kumar v. State of Bihar, (2020) 3 SCC 443, in which material contradictions, absence of supporting medical or independent evidence, and a possible motive for false implication justified extending the benefit of doubt to the accused.

The Court found material discrepancies between the prosecutrix’s written report and her deposition: the written report stated that the appellant dragged her on a bicycle, whereas in deposition she stated that he came on foot, gagged her, and carried her on his shoulder.

There were also inconsistencies concerning the place of occurrence, the manner in which she was taken away, and the distance between the relevant locations.

The medical examination conducted shortly after the occurrence revealed only a simple abrasion on the knee; the hymen was intact, there was no injury to the private parts, no sign of rape, and no spermatozoa was detected in the vaginal swab.

The doctor opined that there was no sign of rape.

Although the Court accepted that the FIR delay had been explained by the villagers’ alleged inability to travel to the police station at night, it held that the cumulative effect of the prosecutrix’s material contradictions, the absence of medical corroboration, and the possible background dispute meant that she did not qualify as a wholly reliable or “sterling” witness.

Consequently, the prosecution had failed to establish guilt beyond reasonable doubt.

Holding that it was unsafe to sustain the conviction on the prosecutrix’s testimony in the presence of material contradictions and contrary medical evidence, the Court extended the benefit of doubt to the appellant.

As he was on bail, he was discharged from the liability of his bail bond and the sureties were also discharged.