Mithun Paul's conviction under Section 376 IPC set aside as court finds prosecution failed to prove case beyond reasonable doubt
In a significant judgment delivered on March 27, 2026, the Calcutta High Court overturned the conviction of Mithun Paul under Section 376 of the Indian Penal Code (IPC), citing insufficient corroborative evidence and the suppression of a marital relationship between the victim and the accused. The decision was rendered by Justice Chaitali Chatterjee Das in response to an appeal against the conviction and sentencing by a lower court.
The case revolved around allegations that Mithun Paul had raped the victim under the false promise of marriage and confined her for nine days. However, during the trial, it was revealed that the victim and the accused had a prior romantic relationship and were subsequently married. The victim's omission of this crucial marital fact in her initial complaint significantly undermined the prosecution's case.
The Court pointed out that the prosecution failed to prove the allegations beyond a reasonable doubt, a fundamental requirement in criminal jurisprudence. The absence of corroborative evidence regarding the victim's confinement and the lack of any complaints from her family further weakened the prosecution's stance. The Court also noted that several key witnesses, to whom the victim purportedly narrated her ordeal, denied having any knowledge of the alleged rape, leading to them being declared hostile.
Moreover, the Court found that the prosecution did not establish the existence of any false promise of marriage that would qualify as a misconception of fact under Section 90 of the IPC. The evidence suggested a consensual relationship, culminating in marriage, which the victim later admitted during cross-examination.
The High Court concluded that the trial court's conviction was based on an incomplete understanding of the facts and failed to consider the romantic and marital context of the relationship. Consequently, the Court set aside the conviction and acquitted Mithun Paul, underscoring the necessity for the prosecution to present a case free from reasonable doubt.
Bottom Line:
Conviction under Section 376 IPC set aside due to lack of corroborative evidence, suppression of marital relationship between victim and accused, and absence of evidence to prove confinement or rape beyond reasonable doubt.
Statutory provision(s): Indian Penal Code, 1860 Sections 376, 90; Code of Criminal Procedure, 1973 Sections 313, 374, 164
Mithun Paul v. State of West Bengal, (Calcutta) : Law Finder Doc id # 2873381
