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The State of Madhya Pradesh v. Rajaram @ Raja

Criminal Appeal · 2018 INSC 986Decided 24 Oct 2018
Criminal Appeal No. 637 of 2016
Justice N.V. Ramana · Justice Mohan M. Shantanagoudar

Background

A young woman died after consuming a poisonous substance in April 2004. On a "Merg" (unnatural death) inquiry, it emerged that the respondent, Rajaram, had allegedly raped her, driving her to suicide out of depression. He was tried and convicted by the trial court under Sections 376(1) (rape) and 306 (abetment of suicide) of the Indian Penal Code and sentenced to 10 years' imprisonment. The Madhya Pradesh High Court later acquitted him on appeal, and the State of Madhya Pradesh challenged that acquittal before the Supreme Court.

Decision Breakdown

The Supreme Court scrutinised the two key prosecution witnesses: the victim's 12-year-old sister, who admitted under cross-examination that she had been "threatened by the police" into giving her statement, and the victim's father, whose own written complaint to police on the day of death made no mention at all of rape or harassment as the cause. Finding both pieces of evidence unreliable and uncorroborated, and applying the settled rule that an appellate court will not interfere with an acquittal unless it is perverse or suffers from a glaring defect, the Court found no such infirmity in the High Court's order and dismissed the State's appeal.

Lesson Learnt

Courts will not overturn an acquittal just because the State disagrees with it: the evidence must be strong enough to show the acquittal was clearly wrong or perverse, and uncorroborated testimony from a witness who may have been pressured or tutored is treated with real caution.

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

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