The Supreme Court reaffirmed the conviction of an accused in a 1984 rape case, stating that the absence of injuries on the victim’s private parts does not automatically weaken the prosecution’s case. The court dismissed an appeal challenging the previous decision, which had upheld the conviction under Sections 376 (rape) and 323 (voluntarily causing hurt) of the IPC. Emphasizing the importance of overall evidence, the court ruled that physical injuries are not the sole determinant of sexual assault cases.

New Delhi: The Supreme Court upheld the conviction of an accused in a 1984 rape case, emphasizing that the lack of injuries on the victim’s private parts does not necessarily undermine the prosecution’s case.
The Court dismissed the appeal challenging the Allahabad High Court’s decision, which had confirmed the conviction under Sections 376 and 323 of the IPC.
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A Bench comprising Justice Sandeep Mehta and Justice Prasanna B Varale stated,
“Merely because in the medical evidence, there are no major injury marks, this cannot be a reason to discard the otherwise reliable evidence of the prosecutrix. It is not necessary that in every case of alleged rape there must be injuries to the private parts of the victim; it depends on the specific facts and circumstances of each case.”
Senior Advocate Shekhar G Devasa represented the Appellant, while AAG K. Parameshwar appeared for the Respondent.
The appeal stemmed from a High Court judgment that upheld the Trial Court’s conviction and sentence. The prosecution claimed that the accused had gagged the victim and committed rape.
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Initially, the victim’s family faced intimidation from the accused’s relatives, delaying the complaint, but a written report was eventually submitted, leading to an FIR under several IPC sections.
The Supreme Court emphasized that the testimony of a rape victim holds significant weight, comparable to that of an injured witness, and can lead to conviction based solely on her account. The Court noted that the victim was continuously threatened by the accused, which coerced her into submission.
It referenced its earlier decision in State of Punjab v. Gurmit Singh (1996), stating,
“If evidence of the prosecutrix inspires confidence, it must be relied upon without seeking corroboration in material particulars.”
The Court rejected the appellant’s argument that the victim’s mother’s alleged character flaws affected the credibility of the victim’s testimony, asserting,
“The question of conviction of the accused for rape of the prosecutrix is independent and distinct… We find no merit in these contentions.”
Ultimately, the Court concluded,
“Guided by law as aforesaid and applying it to the facts and circumstances of the present case, we find no reason to interfere with the judgment of the High Court which is hereby affirmed. The appeal is dismissed accordingly.”