Rape conviction is unsustainable where the prosecutrix’s uncorroborated testimony fails the "sterling witness" standard.

The appellant was convicted by the Third Additional Sessions Judge, Ambikapur, on 10.08.2007 for offences under Sections 376(1), 450, 342, and 323 of the IPC.

The prosecution alleged that on 15.03.2006, during Holi, the appellant entered the prosecutrix’s house while she was alone, locked the door from inside, and committed forcible sexual intercourse while causing physical injuries by biting her.

The prosecutrix claimed she subsequently informed her sister, husband, and the village Sarpanch.

The appellant challenged the conviction, arguing that the prosecutrix was a consenting party, as she failed to raise an alarm despite neighbors being present, and that the medical evidence contradicted her claims.

1. Whether the testimony of the prosecutrix is of "sterling quality" to sustain a conviction solely on her solitary evidence.

2. Whether the prosecution proved its case beyond reasonable doubt in the absence of medical corroboration, FSL reports, and the examination of key witnesses.

The court primarily applied Sections 376(1), 450, 342, and 323 of the IPC.

The court relied on the "sterling witness" doctrine as defined in Rai Sandeep Alias Deepu v. State (NCT of Delhi), which requires a witness to be of such high quality that their version is unassailable and consistent from the initial statement through cross-examination.

It further applied the principles from Santosh Prasad Alias Santosh Kumar v. State of Bihar and Krishan Kumar Malik v. State of Haryana, which establish that if a prosecutrix's evidence lacks trustworthiness or shows material lacunae, independent corroboration is necessary for conviction.

The High Court found the prosecutrix’s testimony unreliable and untrustworthy. The court noted significant discrepancies: the prosecutrix admitted she did not raise an alarm despite her brother-in-law living in the adjacent house.

Medical evidence from PW-02 contradicted the prosecutrix's claims of biting and physical struggle, as no external or internal injuries were found.

Additionally, the prosecution failed to examine vital witnesses—the prosecutrix's husband and sister—to whom the incident was allegedly reported immediately.

The Sarpanch (PW-01) turned hostile, testifying that the prosecutrix had only mentioned a scuffle, not rape.

Furthermore, no FSL report was produced to confirm the presence of spermatozoa on seized items.

Applying the Rai Sandeep standard, the court determined the prosecutrix was not a "sterling witness" due to these evidentiary gaps and the lack of independent corroboration.

The court held that the evidence was insufficient to sustain the conviction as the prosecutrix's testimony failed to inspire confidence and was not corroborated by medical or scientific evidence.

The appellant was acquitted of all charges under Sections 376(1), 450, 342, and 323 of the IPC.

Under Section 481 of the BNSS 2023, the appellant was directed to furnish a personal bond of Rs. 25,000 for six months to ensure appearance before the Supreme Court if required.