Keshav v. State of Maharashtra

Criminal Appeal · 2025 INSC 603Decided 30 Apr 2025
Crl.A. No.-002321-002321 - 2025 (arising out of SLP(Crl.) No. 11566 of 2024)
Justice Sudhanshu Dhulia · Justice K. Vinod Chandran

Background

Two sisters-in-law, after a quarrel with their mother-in-law, left their matrimonial home along with a two-year-old child and boarded a tempo (a small transport vehicle) to go to Kurla. The prosecution alleged that the accused, who were travelling in the same tempo, refused to stop, threatened the women with a knife, took them to a field, and raped them, after which the women stayed away from home for about two weeks before returning and lodging an FIR. The trial court convicted the appellants (along with two others who were later acquitted on appeal) based on the victims' testimony, and the High Court upheld the conviction.

Decision Breakdown

The Supreme Court re-examined the victims' testimony in detail and found it riddled with unexplained inconsistencies, including contradictory accounts of where and with whom they stayed for two weeks after the alleged rape, no witnesses from the matrimonial home to confirm they left without informing anyone, and a key witness who saw the women in the tempo but could not identify any of the accused as being present. The medical examination also found no evidence of forceful intercourse, though this occurred after some delay. Applying the settled principle that a rape conviction can rest on the victim's testimony alone only if that testimony has a "sterling quality" that inspires confidence, or is otherwise corroborated, the Court found neither condition met here and held that the prosecution's story raised a reasonable doubt. It set aside the convictions and acquitted the accused.

Lesson Learnt

In a rape case, a conviction can rest solely on the victim's testimony, but only if that testimony is consistent, credible and free of the kind of unexplained contradictions that raise genuine doubt. Courts must protect the accused from false implication just as seriously as they must support genuine victims.

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