Rajendra v. State of Uttarakhand
Background
The appellants (Rajendra and three others) were convicted by the Additional Sessions Judge, Dehradun, under Sections 376(2)(g) and 506 IPC for allegedly gang-raping the complainant near Sanjay Colony on 7 April 1998, based on an FIR lodged by her over three months later, on 31 July 1998. The Uttarakhand High Court upheld the conviction, sentencing each accused to 10 years' rigorous imprisonment. The appellants challenged the conviction before the Supreme Court, arguing there was no supporting medical or DNA evidence and that the prolonged, unexplained delay in filing the FIR undermined the prosecutrix's sole testimony.
Decision Breakdown
The Supreme Court held that convicting solely on the prosecutrix's testimony was unsafe in this case given the roughly seven-month delay in lodging the FIR, the absence of any medical evidence or injury records corroborating the incident, and the lack of any DNA test to establish paternity of a child allegedly born from the incident. Relying on its precedent in a similar case (Vijayan), the Court found that where a prosecutrix delays reporting rape for several months and no medical or forensic corroboration exists, convicting solely on her testimony leaves the accused effectively defenceless. The Court concluded the prosecution had not proved its case beyond reasonable doubt, allowed the appeal, set aside the conviction and sentence, and directed the appellants' release if not held for any other offence.
Lesson Learnt
While the sole testimony of a survivor can in principle sustain a conviction, courts require some corroborating evidence or a credible explanation for a lengthy, unexplained delay in reporting before relying on that testimony alone: this protects both genuine survivors' credibility and an accused's right to a fair trial.