VidhiSangh

Supreme Court of India · 17/03/2025

STATE OF RAJASTHAN versus CHATRA

[2025] 4 S.C.R. 95 · 2025 INSC 360

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Summary

A three-year-old girl was found unconscious and bleeding in 1986 after the accused, to whose care she had been entrusted, allegedly raped her. The Sessions Judge convicted him under Section 376 IPC in 1987; the High Court acquitted him in 2013 in a six-page judgment relying on the child's silence in court, a discrepancy between the FIR and the complainant's deposition, and the absence of semen. The Supreme Court restored the conviction: the High Court as first appellate court had not independently assessed the evidence; a traumatised child's silence cannot benefit the accused and conviction may rest on medical and circumstantial evidence; the discrepancy was never put to the witness and was not material; and the medical evidence of injuries to the victim and to the accused pointed to the accused.

Issues

  1. Whether the High Court, as the first appellate court, was justified in reversing the conviction without independently assessing the evidence, and whether the Supreme Court should remand or itself examine the evidence after nearly four decades.
  2. How the silence of a child victim who could not depose about the incident, and the absence of the prosecutrix's testimony generally, bear on the prosecution case.
  3. Whether the discrepancy between the complainant's version in the FIR and his deposition in court was material enough to discredit him.
  4. Whether the medical and circumstantial evidence established the offence under Section 376 IPC beyond reasonable doubt.

Provisions considered

Held

Result

Appeal allowed. The High Court's judgment of acquittal in S.B. Criminal Appeal No. 503/1987 set aside and the Sessions Judge, Tonk's judgment of conviction dated 19 November 1987 in Sessions Trial No. 26/86 restored; the accused to surrender within four weeks to serve the sentence, if not already served. Pending applications closed; original records to be returned.

Judgment PDF: Supreme Court of India, [2025] 4 S.C.R. 95.