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Raju @ Umakant v. The State of Madhya Pradesh

Criminal Appeal · 2025 INSC 615Decided 1 May 2025
Criminal Appeal arising out of SLP (Crl.) No. 17398 of 2024 (C.A. No. 002377-002377 of 2025)
Justice Sanjay Karol · Justice K.V. Viswanathan

Background

In 2004, the appellant and a co-accused were alleged to have abducted a young woman returning from a wedding procession and confined and raped her over several days at different locations. She was recovered by police two days later. The Trial Court convicted the appellant of abduction, gang rape and wrongful confinement, and separately convicted him under the SC/ST Act on the basis that the victim belonged to a Scheduled Caste; the High Court affirmed the conviction and life sentence.

Decision Breakdown

The Supreme Court upheld the core convictions for abduction, gang rape and wrongful confinement, holding that the victim's clear, consistent testimony was sufficient on its own to sustain a rape conviction without corroboration, and rejecting the defence's claim of consent given the statutory presumption against consent in gang-rape cases. However, it acquitted the appellant of the SC/ST Act charge, finding no evidence that the crime was committed specifically because the victim belonged to a Scheduled Caste: mere knowledge of her caste, without that being a ground for the offence, is not enough under the unamended provision. To bring parity with the co-accused's sentence, the Court reduced the life sentence for gang rape to ten years' rigorous imprisonment, while also criticising the outdated and degrading "two-finger test" used in the victim's medical examination.

Lesson Learnt

A survivor's own credible testimony can be enough to convict for rape without any other corroboration; but an enhanced SC/ST Act charge requires actual proof that the crime was committed because of the victim's caste identity, not just that the accused knew of it.

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

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