Summary
The Supreme Court acquitted an accused of rape and house-trespass on benefit of doubt. A conviction may rest on the complainant’s sole testimony if reliable and confidence-inspiring, but the testimony here contained material inconsistencies and an unconvincing account of the occurrence. The Court assessed these defects together with the inconclusive scientific evidence, unsupported medical findings and admitted land dispute. Its conclusion rested on the cumulative facts, not a universal requirement of corroboration.
Issues
- Whether the complainant’s sole testimony was sufficiently reliable to sustain conviction on this record.
Held
- Reliable, trustworthy and confidence-inspiring testimony of a complainant can by itself sustain a rape conviction. The inquiry concerns the quality and consistency of the evidence, rather than a mandatory requirement for independent corroboration in every case. (¶¶ 5.3, 5.4.1, 5.4.2, 5.4.3, 5.5)
- Here material discrepancies concerned the manner of the occurrence and the form and timing of the complaint. The asserted means of identification and entry were unsupported, other evidence did not support the prosecution version and an existing land dispute was admitted. Considered cumulatively, the sole testimony did not safely sustain the convictions. (¶¶ 5.2, 5.3, 6)
- The inconclusive forensic report and absence of medical support were evaluated alongside the testimonial defects. The Court gave benefit of doubt on the whole record; it did not treat absence of injuries or forensic confirmation as invariably disproving rape. (¶¶ 5.2, 5.3, 6)
Result
Appeal allowed; convictions and sentences under Sections 376(1) and 450 IPC set aside. Accused acquitted of all charges and directed to be released forthwith unless required in another case.