Internal Contradictions and Lack of Sterling Testimony in Sexual Assault Cases Warrant Upholding Acquittal

The appellant (victim) filed an FIR on 16.02.2019, alleging that on 18.01.2019, the accused forcibly raped her in a mustard field and recorded a video to blackmail her into subsequent acts.

She further alleged that on 20.01.2019, she was lured by the accused's sister and taken toward Delhi for trafficking but escaped with her cousin’s help.

The Trial Court acquitted the respondent of charges under Sections 376 and 506 of the IPC on 12.03.2026.

The victim appealed this acquittal, contending the Trial Court ignored the "sterling" testimony of the prosecutrix.

1. Whether the Trial Court’s judgment of acquittal was perverse, illegal, or suffered from a manifest error of fact or law warranting interference by the Appellate Court.

2. Whether the testimony of the prosecutrix qualifies as a "sterling witness" sufficient to prove the charges of rape and criminal intimidation beyond reasonable doubt.

The Court primarily applied Sections 376 (Rape) and 506 (Criminal Intimidation) of the IPC.

Regarding the scope of appeals against acquittal, it relied on Chandrappa v. State of Karnataka, which established that while appellate courts have full power to review evidence, they must respect the "double presumption" of innocence reinforced by acquittal and should not disturb a "possible view" taken by the Trial Court.

It further applied the "sterling witness" test from Manjunath v. State of Karnataka, requiring a witness's version to be unassailable, consistent, and of very high quality to sustain a conviction without corroboration.

The Court found the prosecutrix’s testimony failed the "sterling witness" test due to material contradictions and improbable conduct. First, while the FIR claimed she was "dragged," her testimony admitted she went to the field voluntarily at the accused's request.

Second, her admission that they both watched the recorded video for 30 minutes after the act and that she cleaned herself at the spot suggested consensual conduct rather than rape.

Third, the Court noted the physical impossibility of the trafficking story, as the victim failed to raise alarms at crowded locations like Kanpur Railway Station.

Fourth, material contradictions existed between the victim’s version and her father’s (PW2) regarding the time she went missing (03:00 AM vs. 09:00 AM).

Finally, the prosecution failed to recover the alleged video or examine the cousins who purportedly rescued the victim.

The Court held that the prosecution failed to prove the guilt of the accused beyond reasonable doubt, specifically noting the consensual nature of the initial encounter and the unreliability of the trafficking allegations. The High Court dismissed the appeal and upheld the judgment of acquittal.