The Supreme Court of India reinstated the conviction of a man accused of raping a minor in 1986, emphasizing the need to recognize a victim’s silent trauma in sexual assault cases.
NEW DELHI: In a landmark judgment, the Supreme Court of India has set aside the acquittal of a man accused of sexually assaulting a minor girl in 1986, nearly four decades ago. The apex court was deciding a criminal appeal filed by the State of Rajasthan against the Rajasthan High Court’s Single Judge ruling, which had acquitted the accused of all charges.
The two-Judge Bench, comprising Justice Vikram Nath and Justice Sanjay Karol, highlighted the profound impact of trauma on victims of sexual assault. The court observed that
“the trial court had noted how the victim, identified as ‘V,’ had remained silent when questioned about the incident, only shedding silent tears”
The Bench emphasized that
“such silence should not be construed as evidence in favor of the accused. Instead, the emotional distress of the victim must be understood for its gravity”
Background of the Case
The alleged incident took place on March 3, 1986, when the minor victim was discovered unconscious and bleeding from her private parts by a witness.
The prosecution alleged that the respondent-accused had subjected her to sexual assault. A complaint was lodged with the local police station, leading to a thorough investigation.
During the trial, the prosecution presented substantial evidence, including testimonies from fifteen witnesses and nineteen documentary exhibits.
However, the accused refuted all allegations, contending that the
“case was fabricated by the witness due to a property dispute involving the victim’s father and the accused”
The Trial Court convicted the accused under Section 376 of the Indian Penal Code (IPC), sentencing him to seven years of rigorous imprisonment along with a fine of Rs. 500/-.
Dissatisfied with this outcome, the accused challenged the verdict before the Rajasthan High Court, which overturned his conviction and acquitted him. The State of Rajasthan, aggrieved by the acquittal, subsequently appealed to the Supreme Court.
Supreme Court’s Observations and Legal Reasoning
After thoroughly reviewing the evidence and hearing the arguments presented by both sides, the Supreme Court expressed
“deep concern over the prolonged struggle faced by the victim and her family in their quest for justice”
The Bench noted with regret that
“the minor victim had endured decades of trauma while awaiting closure to this harrowing chapter of her life”
A critical aspect of the case was the victim’s silence during her testimony. The Supreme Court held that
“Her silence was not indicative of falsehood or inconsistency but rather a manifestation of profound trauma”
The court ruled that
“Her inability to testify explicitly against the accused should not serve as a basis to weaken the prosecution’s case”
The Bench observed:
“V has not turned hostile. Trauma has engulfed her in silence. It would be unfair to burden her young shoulders with the weight of the entire prosecution. A child traumatized at a tender age by this ghastly imposition upon her has to be relieved of being the basis on which her offender can be put behind bars.”
The Court further clarified that
“while a victim’s testimony often plays a crucial role in securing a conviction, it is not an absolute necessity in every case. If other compelling evidence—such as medical and circumstantial evidence—is available, the absence of a direct testimony does not preclude a conviction”
The Bench stated that
“the judicial process must be sensitive to the realities of trauma, especially when dealing with child victims of sexual abuse”
The defense attempted to
“discredit the prosecution’s case by suggesting alternative causes for the injuries sustained by the victim, including an accidental injury caused by a nail or pin“
Additionally, the defense alleged that the medical examiner’s findings were influenced by bribery. The Court, however, dismissed these arguments, noting that there was
” no substantial evidence to support these claims”
Furthermore, medical evidence demonstrated that the nature of the injuries sustained by both the victim and the accused was consistent with forceful sexual intercourse. The Court also pointed out that
“the alleged animosity between the accused and the victim’s father was insufficient to establish a reasonable doubt in the prosecution’s case“
Verdict and Conclusion
After considering all aspects of the case, the Supreme Court allowed the State’s appeal, set aside the Rajasthan High Court’s acquittal, and reinstated the conviction and sentence awarded by the Trial Court. The Bench’s ruling reaffirmed
“the judiciary’s commitment to ensuring justice for victims of sexual violence, particularly in cases where trauma impairs the victim’s ability to provide explicit testimony”
The judgment sets a precedent by recognizing that a victim’s silence—particularly that of a child—must not be interpreted as a sign of falsehood or weakness in the prosecution’s case. Instead, courts must take a holistic approach, evaluating all available evidence to arrive at a just conclusion.
This ruling stands as a significant step in upholding the rights of survivors and ensuring that their pain and trauma are given due consideration in legal proceedings.
Cause Title: State of Rajasthan v. Chatra (Neutral Citation: 2025 INSC 360)
Legal Representation:
- For the Appellant/State: AAG Sanskriti Pathak, AOR Milind Kumar, and Advocate Aman Prasad
- For the Respondent/Accused: AOR Ranbir Singh Yadav, Advocates Prateek Yadav, Puran Mal Saini, Anzu K. Varkey, and Pratima Yadav
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