Phool Singh v. The State of Madhya Pradesh

Criminal Appeal · 2021 INSC 812Decided 1 Dec 2021
Criminal Appeal No. 1520 of 2021
Justice M.R. Shah · Justice Sanjiv Khanna

Background

The accused was convicted of raping his relative after entering her room at night while her husband was away. She initially told her sister-in-law and mother-in-law, who disbelieved her and beat her instead of helping, leading to a three-day delay before the FIR was filed at her parental home. The trial court convicted him based on her testimony and disbelieved his alibi defence, sentencing him to the mandatory minimum of 7 years' rigorous imprisonment, and the Madhya Pradesh High Court confirmed this on appeal.

Decision Breakdown

The Supreme Court dismissed the appeal and upheld the conviction and sentence. It held that the absence of external or internal injuries does not automatically suggest consent, and that a sexual assault survivor's sole testimony, if found credible and trustworthy, is sufficient to sustain a conviction without requiring independent corroboration. The Court also found no error in rejecting the alibi defence, since the accused failed to produce any independent witness or documentary evidence to support it, and found the delay in filing the FIR fully explained by the family's initial disbelief and hostility toward the victim. It declined to reduce the sentence below the statutory minimum, finding no special or adequate reasons to do so.

Lesson Learnt

Courts can and do convict based solely on a credible survivor's testimony in sexual assault cases without demanding corroborating evidence, and a delay in reporting caused by family members disbelieving the victim does not weaken the case against the accused.

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