Contradictions in Testimony and Lack of Corroborative Evidence Lead to Acquittal of Accused Amit Shahani
In a significant ruling, the Allahabad High Court, Lucknow Bench, dismissed a criminal appeal challenging the acquittal of Amit Shahani, who was accused of charges including rape, abduction, and criminal intimidation. The decision, pronounced on May 21, 2026, by the Division Bench comprising Justices Abdul Moin and Pramod Kumar Srivastava, upheld the trial court's judgment due to inconsistencies in the prosecution's case and lack of credible evidence.
The case, originally stemming from an FIR filed in Ambedkar Nagar in January 2023, involved serious allegations against Amit Shahani, who was accused of orchestrating a series of crimes against the appellant, referred to as Victim X. The prosecution's narrative detailed a harrowing ordeal where Victim X was allegedly abducted, threatened, and raped over a period extending from January 23 to February 14, 2023.
However, the trial court had acquitted Shahani, citing significant contradictions in the victim's testimony, discrepancies between her statements, and a lack of corroborative medical evidence. The prosecutrix’s failure to raise an alarm or seek help during her journey with the accused, as well as the absence of any physical injuries, were pivotal in the trial court's decision.
During the appeal, the High Court scrutinized the trial court's judgment and the evidentiary records. The Bench emphasized the legal principles established by the Supreme Court regarding the evaluation of a prosecutrix's testimony in rape cases, particularly the necessity for such testimony to be of "sterling quality." The court found that the victim's testimony did not meet this standard, as it was fraught with contradictions and lacked the consistency required to form the basis of a conviction without corroboration.
The judgment also highlighted the medical evidence, or lack thereof, noting that the medical examination did not support the allegations of rape. The court reiterated that while corroborative evidence is not always necessary in rape cases, the testimony must still inspire confidence and be free of material contradictions.
The High Court concluded that the trial court's judgment was logical, probable, and based on valid reasons, thus warranting no interference. The appeal was dismissed, affirming the acquittal of Amit Shahani, and underscoring the importance of credible and consistent evidence in criminal proceedings.
Bottom line:-
Testimony of the prosecutrix in rape cases must inspire confidence of the court. Sole testimony of prosecutrix can form the basis of conviction if it is of sterling quality and free from inconsistencies or contradictions. However, contradictions, lack of corroboration, and absence of credible evidence can lead to acquittal.
Statutory provision(s): Indian Penal Code Sections 342, 366, 376, 506, 120B; Evidence Act, 1872 Section 114A; Criminal Procedure Code, 1973 Section 372
Informant/Complainant (Victim X) v. State of U.P., (Allahabad)(DB)(Lucknow) : Law Finder Doc id # 2904642https://www.lawfinderlive.com/News.aspx?v=llCzo%2bgFMw%2fPGy899vTung%3d%3d
