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Munna v. State of Madhya Pradesh

Criminal Appeal · Neutral citation not assigned (Criminal Appeal No. 2358 of 2010)Decided 16 Sept 2014
Criminal Appeal No. 2358 of 2010
Justice V. Gopala Gowda · Justice Adarsh Kumar Goel

Background

Munna was convicted of entering a woman's house at night and raping her, and the High Court upheld seven-year concurrent sentences. The complainant had initially accused two men, later exonerated them in an affidavit, and then gave a trial account implicating Munna alone. The defence also identified inconsistent accounts about when the accused left the house.

Decision Breakdown

The Supreme Court acquitted Munna after considering the contradictions together with the rest of the record. It reiterated that a reliable sexual-assault complainant's testimony can support conviction without mandatory corroboration. Lack of injuries, delay or failure to raise an alarm did not individually establish falsity. Here, however, the retraction and substantial inconsistencies created reasonable doubt about the prosecution account as a whole.

Lesson Learnt

Sexual-assault testimony is not automatically suspect and does not routinely need independent corroboration. A conviction still requires reliable proof, and material inconsistencies must be assessed in the particular case.

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

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