Jharkhand High Court Upholds Rape Conviction Based on Sole Testimony of Victim

The court reaffirms that the victim's credible testimony suffices for conviction, dismissing the need for corroboration in rape cases.

In a significant judgment, the Jharkhand High Court has upheld the conviction of Rabindra Prasad @ Rabindra Prasad Bhagat for rape, relying solely on the testimony of the victim. The case, which has spanned over two decades, was decided by Justice Arun Kumar Rai, who emphasized that the victim's testimony inspired confidence and was consistent, thereby negating the necessity for additional corroborative evidence.

The case originated from an incident on March 12, 2002, when the victim, a 14-year-old girl, was raped by the accused near a mela site. The victim's immediate disclosure to her mother and aunt was considered relevant under Section 6 of the Indian Evidence Act, strengthening her credibility. Despite the delayed filing of the First Information Report (FIR), the court acknowledged the societal pressures and attempts at resolving the issue through village panchayat meetings as reasonable explanations for the delay.

The defense argued that the victim was a consenting adult, challenging the age determination based on ossification tests. However, the court prioritized the school-issued age certificate, confirming the victim was a minor, thereby invalidating any consent as per the law.

The court reiterated established legal precedents that the sole testimony of a rape victim could suffice for conviction if it is credible and compelling. It dismissed the defense's claims of enmity and false implication, finding no substantial evidence to undermine the victim's account.

Ultimately, the court dismissed the appeal and ordered the appellant to surrender immediately to serve his seven-year sentence. This judgment reinforces the judiciary's commitment to addressing sexual crimes with sensitivity and upholding the victim's testimony when it meets the threshold of credibility and consistency.

Bottom Line:

In cases of rape, the testimony of the victim, if it inspires confidence and does not suffer from any infirmity, is sufficient to convict the accused without requiring corroboration from medical evidence or other sources.

Statutory provision(s): Indian Penal Code, 1860 - Section 376; Indian Evidence Act, 1872 - Section 6.

Rabindra Prasad @ Rabindra Prasad Bhagat v. State of Jharkhand, (Jharkhand) : Law Finder Doc Id # 2820809