Rape conviction unsustainable where solitary testimony of prosecutrix fails the test of ‘sterling quality’.

The appellant was convicted by the District and Sessions Judge, Rajnandgaon, on 31.03.2005 for offences under Sections 376(1) and 506-B of the IPC.

The prosecution alleged that on 08.11.2003, while the victim's parents were away, the appellant forcibly dragged the 20-year-old victim from her courtyard to a nearby field, threatened to kill her, and committed rape.

An FIR was lodged on 16.11.2003, following an eight-day delay attributed to a village Panchayat meeting where the appellant denied the allegations.

Medical examinations and FSL reports were conducted, and the trial court found the appellant guilty primarily based on the victim’s testimony.

The appellant challenged this conviction, citing the delay in FIR, lack of medical corroboration, and evidence suggesting the victim was a consenting party.

1. Whether a conviction for rape can be recorded solely on the testimony of the victim if it lacks "sterling quality."

2. Whether the prosecution proved the charges of rape and criminal intimidation beyond a reasonable doubt given the material contradictions and subsequent conduct of the parties.

Section 376(1) (punishment for rape) and Section 506-B (criminal intimidation) of the IPC.

The "Sterling Witness" doctrine, established in Santosh Prasad v. State of Bihar (2020) and Nirmal Premkumar v. State (2024), which mandates that while a conviction can be based on the sole testimony of a victim, such testimony must be absolutely trustworthy, consistent, and unblemished to dispense with the need for corroboration.

Section 480 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (BNSS) regarding the discharge of bail bonds upon acquittal.

The High Court determined that the victim’s testimony failed the test of a "sterling witness" due to several factors.

First, the medical evidence (PW-9) showed no injuries on the victim and the FSL report (Ex.P/12) was negative, contradicting the claim of a struggle.

Second, the court noted that the scene of the incident was in a densely populated area where an alarm would have been heard, yet no such alarm was reported by neighbors.

Third, the court highlighted significant evidence of subsequent conduct: the victim and appellant were "caught together" in a room days after the incident, and the victim lived with the appellant for 8–10 days.

Crucially, the victim admitted she only filed the FIR because the appellant eventually refused to keep/marry her.

The court concluded these factors pointed toward a consensual relationship rather than a forceful assault, creating a reasonable doubt.

The conviction and sentence under Sections 376(1) and 506-B IPC were set aside, and the appellant was granted the benefit of doubt.

The appeal was allowed, the appellant was acquitted, and his bail bonds were discharged pursuant to Section 480 of the BNSS.