Conviction may be based on the uncorroborated testimony of a minor victim if it proves consistent and trustworthy.

The Appellant, the victim’s stepfather, was accused of repeated sexual abuse and rape of the minor victim (PW-9) between 2014 and 2015.

The incidents involved forced oral sex, penetration of the urinary tract and vagina, and physical violence.

The matter came to light in December 2015 when the victim disclosed the abuse to Child Line personnel (PW-6) during a school awareness program.

The Trial Court convicted the Appellant under Section 377 of the IPC and Sections 5(l)/6, 5(m)/6, and 5(n)/6 of the POCSO Act, sentencing him to life imprisonment.

The Appellant challenged the conviction, alleging material contradictions in the child witness's testimony and a lack of corroborating medical evidence.

1. Whether the prosecution successfully established that the victim was a "child" as defined under Section 2(d) of the POCSO Act at the time of the incident?

2. Whether the sole testimony of a minor victim can form the basis of conviction in the absence of independent corroboration?

3. Whether the prosecution proved the guilt of the Appellant beyond reasonable doubt despite alleged inconsistencies?

The Court applied Section 2(d) of the POCSO Act, defining a child as any person below eighteen years.

Regarding the weight of evidence, the Court relied on Rameshwar v. State of Rajasthan, establishing that corroboration is a rule of prudence, not an absolute rule of law.

It further applied the "Sterling Witness" test from Rai Sandeep @ Deenu v. State of NCT of Delhi, requiring a witness's version to be unassailable and consistent.

The Court also referenced Nawabuddin v. State of Uttarakhand [para 30] and Ranjit Hazarika v. State of Assam [para 28], which equate the testimony of a sexual assault victim to that of an "injured witness," deserving high evidentiary value.

The Court first determined the victim's age as approximately nine years at the start of the abuse, based on the Dakhil-Kharij register (Ex.P-13C) which recorded her birth date as 04.07.2006.

In analyzing the testimony of PW-9, the Court found her account of the sexual abuse, including the penetration of her "urinator" and the use of threats, to be natural, cogent, and consistent with her statement under Section 164 CrPC (Ex.P-7).

The Court dismissed the Appellant's argument regarding the lack of medical corroboration, noting that in cases of sexual assault, the victim's testimony—if found to be of "sterling quality"—is sufficient for conviction.

The Court observed that the victim’s initial silence and subsequent disclosure upon meeting Child Line workers were consistent with the behavioral patterns of children abused by family members.

The findings were further supported by the testimony of Manish Kushwaha (PW-6) regarding the circumstances of the disclosure.

The Court upheld the conviction and life imprisonment sentences under the IPC and POCSO Act.

The appeal was dismissed, the Appellant's bail bonds were cancelled, and he was ordered to surrender within four weeks to serve the remainder of his sentence.