SC Reaffirms Conviction Based Solely on Credible Victim Testimony in Rape Cases

The Supreme Court has once again underscored a vital principle in sexual offence cases — the credible testimony of a rape victim, when consistent and trustworthy, is sufficient for conviction even without medical corroboration.

Case Background

On 3 April 2018, a 15-year-old girl and her 11-year-old brother were alone at home in Chhattisgarh when the appellant, Deepak Kumar Sahu, entered, sent the boy away to buy tobacco, and sexually assaulted the girl. The victim immediately informed her cousin and parents, who lodged a police complaint.

The Special Judge (SC/ST Court), Rajnandgaon, convicted Sahu under Section 376(2) IPC and Section 4 of the POCSO Act, sentencing him to 10 years’ rigorous imprisonment. The High Court upheld the conviction.

Appellant’s Grounds of Challenge

Medical Evidence Deficiency – No external injury marks on the victim’s genitals.
Credibility of Victim’s Statement – Testimony should be treated cautiously without categorical medical confirmation.
Victim’s Age – Alleged failure to prove minority, crucial for invoking POCSO.

Supreme Court’s Findings

Victim’s Age

The Court termed the age challenge “to be stated to be rejected,” relying on the victim’s 8th standard marksheet showing her birth date as 09.10.2002, corroborated by parents’ and IO’s testimony, establishing her age as 15 years, 5 months, 24 days on the date of offence.

Primacy of Victim Testimony

Reiterating settled law, the Court held:

“In cases of rape, the testimony of the prosecutrix alone may be sufficient when cogent and consistent.”

The victim’s account was clear, consistent, and natural, with conduct post-incident (immediate disclosure) lending further credibility.

Role of Medical Evidence

The Court ruled that insufficiency or absence of medical corroboration does not nullify credible victim testimony. Though no injury marks were found, a ruptured and healing hymen was noted.

Precedents Cited

State of Punjab v. Gurmit Singh (1996) – Absence of injuries no ground to doubt rape.
Lok Mal v. State of UP (2025) – Lack of major injuries not fatal to credible testimony.
Wahid Khan v. State of MP (2010) – Slightest penetration is rape under Section 375 IPC.
State of HP v. Manga Singh (2019) – Corroboration not mandatory in rape cases.
Bharwada Bhoginbhai v. State of Gujarat (1983) – Rejecting corroboration as a rule avoids “adding insult to injury.”

Key Principles Reaffirmed

A rape victim is an injured witness, not an accomplice; her testimony deserves special weight.
Consistency, credibility, and natural conduct are benchmarks for assessing testimony.
Corroboration is optional, not compulsory, if testimony inspires confidence.
Minor inconsistencies can indicate truth rather than fabrication.

Societal & Legal Impact

The Court warned that unwarranted acquittals “encourage wolves in society” and recognised the severe psychological impact of rape. This ruling:

Strengthens survivor protection by reducing reliance on often-unavailable medical evidence.
Addresses systemic barriers like delayed reporting, private nature of crime, and victim trauma.
Provides clear procedural safeguards — courts must still examine testimony with caution and care.

Conclusion

By upholding the conviction solely on the victim’s credible statement, the Supreme Court:

Reinforced established legal precedent.
Reduced unnecessary evidentiary burdens.
Sent a strong societal message on protecting survivors.

The Court found the victim’s testimony “entirely probable, natural, and trustworthy,” leaving “no reason… to disbelieve and discard” it — cementing the role of victim testimony as a cornerstone in sexual assault prosecutions.

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