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Deepak Kumar Sahu v. State of Chhattisgarh

Criminal Appeal · 2025 INSC 929Decided 5 Aug 2025
Criminal Appeal arising out of SLP (Crl.) (D) No. 26453 of 2025
Justice Sudhanshu Dhulia · Justice N.V. Anjaria

Background

The appellant was convicted of house trespass, sexual assault of a minor under the POCSO Act, and rape under Section 376(2) IPC, for an incident in which he entered the house of a 15-year-old girl while her parents were away, sent her younger brother out on an errand, and assaulted her. The victim immediately told her cousin and, through her, contacted her parents, leading to a police complaint. The trial court and the Chhattisgarh High Court both convicted and sentenced him, and he appealed to the Supreme Court arguing the medical evidence was inconclusive and there were contradictions between the victim's and her brother's testimony.

Decision Breakdown

The Court held that the victim was proved to be a minor (15 years old) through her school marksheet and her parents' evidence, rejecting the age-related defence. It found the victim's testimony natural, consistent, and corroborated by her young brother (an eyewitness) and other family members, and reaffirmed settled law that a conviction for rape can rest on the sole, credible testimony of the prosecutrix even without corroborating medical evidence, citing a long line of precedents including State of Punjab v. Gurmit Singh and Lok Mal v. State of Uttar Pradesh. The absence of external injuries or conclusive medical findings did not undermine the victim's credible account. The appeal was dismissed and the conviction upheld.

Lesson Learnt

In sexual assault cases, courts can and do convict based solely on a credible victim's testimony: the absence of physical injury or corroborating medical evidence does not by itself create reasonable doubt.

Official source (sci.gov.in)View Judgment (PDF)

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