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Ganga Prasad Mahto v. State of Bihar & Anr.

Criminal Appeal · 2019 INSC 402Decided 26 Mar 2019
Criminal Appeal No. 526 of 2019
Justice Abhay Manohar Sapre · Justice Dinesh Maheshwari

Background

The appellant was convicted under Section 376 IPC (rape) and sentenced to seven years' rigorous imprisonment by a Sessions Court, based on a complaint that he had entered the complainant's house at night, threatened her with a pistol, and raped her while she was alone. The Patna High Court upheld the conviction. The appellant challenged his concurrent conviction before the Supreme Court.

Decision Breakdown

The Supreme Court found the prosecution had failed to prove the charge beyond reasonable doubt for several converging reasons: the complainant was never medically examined after the alleged incident and no doctor was called as a witness; it was undisputed that the complainant had made similar complaints against other persons in the past that were later found to be false; there was pre-existing enmity between the appellant and the complainant's husband; the complainant had a pattern of making such allegations against people she or her husband had disputes with; the sole supporting witness was a "chance witness" whose testimony could not establish a rape charge by itself; and the complainant's husband admitted he was away from the village and returned only the next morning. Weighing these facts together, the Court held both lower courts were wrong to convict, set aside the conviction and sentence, and acquitted the appellant, ordering him released and his bail bonds discharged.

Lesson Learnt

A criminal conviction, especially for a serious offence like rape, cannot rest on an uncorroborated complaint alone where there is no medical evidence, a documented history of similar false complaints by the complainant, clear motive for false implication, and only a weak "chance witness" to rely on: courts must insist on proof beyond reasonable doubt, not merely a plausible allegation.

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

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