Sole testimony of a minor victim is sufficient for conviction if found reliable and trustworthy.

The appellant, the victim’s cousin, was accused of multiple instances of forcible sexual intercourse with the victim (PW1), a 14-year-old minor, between 2015 and 2016 while they resided together.

In September 2016, the victim fled to a forest area due to physical pain and fear of pregnancy, where she was discovered by PW4.

Initially, following instructions from the appellant, the victim claimed she was kidnapped and raped by four individuals; however, she later disclosed the appellant's sole involvement to her parents and medical examiners.

The Trial Court convicted the appellant under Section 6 of the POCSO Act, sentencing him to 10 years of rigorous imprisonment.

The appellant challenged the conviction citing delay in FIR, lack of corroboration, and alleged matrimonial/property enmity.

1. Whether the sole testimony of the minor victim is sufficient for conviction in the absence of material corroboration and in light of initial inconsistent statements.

2. Whether the delay in lodging the FIR and registering the case is fatal to the prosecution's version.

3. Whether the statutory presumption under Section 29 of the POCSO Act was correctly applied against the accused.

The Court primarily applied Section 6 (Aggravated Penetrative Sexual Assault) and Section 29 (Presumption as to certain offences) of the POCSO Act, 2012.

It relied on the "Sterling Witness" doctrine established in *Ganesan v. State* (2020) and *Rai Sandeep v. State (NCT of Delhi)* (2012), which holds that a conviction can be based on the sole, trustworthy testimony of a prosecutrix if it is of sterling quality.

The Court also referenced *Bhanei Prasad alias Raju v. State of Himachal Pradesh* (2025) regarding the lack of mitigation in cases of incestuous sexual violence.

The Court found the victim’s testimony regarding the sexual relationship consistent across her complaint (Ex.P1), Section 164 CrPC statement (Ex.P2), and oral evidence.

It reasoned that her initial "kidnap" story was a result of trauma and the appellant’s influence, which she rectified during medical examination (Ex.P8).

The Court held that minor discrepancies do not vitiate the core testimony of a minor victim who faced "shame in the family and society".

Scientifically, while the Doctor (PW9) noted the hymen was not intact, the Court emphasized that in POCSO cases, consent is immaterial and the established "foundational facts" triggered the Section 29 presumption.

The Court dismissed the "enmity" defense, noting the appellant failed to lead any rebuttal evidence to dislodge the statutory presumption.

The Court ruled that the testimony of the victim was of "sterling quality" and required no further corroboration.

The appeal was dismissed, the conviction and 10-year sentence were upheld, and the Trial Court was directed to secure the accused to undergo the remainder of the sentence.