VidhiSangh

Supreme Court of India · 01/12/2021

PHOOL SINGH versus THE STATE OF MADHYA PRADESH

[2021] 9 S.C.R. 317 · 2021 INSC 812

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Summary

The Court affirmed a rape conviction and seven years’ rigorous imprisonment on the survivor’s consistent and trustworthy testimony. Corroboration is not an invariable legal requirement where that testimony inspires confidence. The unsupported consent suggestion, rejected alibi and explained delay in reporting did not undermine the prosecution. The Court found no adequate special reason under the applicable pre-amendment provision to reduce the sentence below seven years, and refused to substitute simple imprisonment.

Issues

  1. Whether the survivor’s sole testimony could sustain conviction despite the asserted lack of corroboration and injuries.
  2. Whether the alibi or delay in reporting justified interference with conviction.
  3. Whether the applicable pre-amendment sentencing proviso justified reducing or altering the imprisonment.

Provisions considered

Held

Result

Appeal dismissed. Conviction under Section 376 IPC, seven years’ rigorous imprisonment and the Rs.500 fine with default stipulation were affirmed.

Judgment PDF: Supreme Court of India, [2021] 9 S.C.R. 317.