The Supreme Court of India has upheld the Himachal Pradesh High Court’s acquittal in a rape case, emphasizing that refusal of a medical examination by the alleged victim can lead to adverse inferences.
NEW DELHI: The Supreme Court of India has reaffirmed the legal principle that the
“refusal of a medical examination by an alleged rape victim can lead to adverse inferences against them”.
This observation was made while dismissing a criminal appeal filed by the State of Himachal Pradesh against an acquittal granted by the Himachal Pradesh High Court in a rape case.
The Division Bench, comprising Justice Surya Kant and Justice Nongmeikapam Kotiswar Singh, held that
“the prosecutrix’s non-cooperation with medical authorities, coupled with inconsistencies in witness testimonies and procedural lapses, significantly weakened the prosecution’s case”
Background of the Case
The case dates back to 2007, when a woman (prosecutrix), through her father, filed an FIR under Sections 452 and 376 of the Indian Penal Code, 1860 (IPC), alleging that the accused forcibly entered her house and committed sexual assault.
Allegations Made in the FIR
According to the FIR, on the day of the incident:
- The prosecutrix’s parents (PW-8 & PW-9) had gone to a hospital to buy medicines, leaving her alone at home.
- The accused, Rajesh Kumar @ Munnu, arrived at her house, asking for a matchbox.
- Finding her alone, he allegedly grabbed her arm, dragged her inside a room, and sexually assaulted her.
- Upon her parents’ return, she narrated the incident to them, following which they reported the matter to the police.
Trial Court Conviction
After conducting the trial, the Sessions Court convicted the accused and sentenced him to 10 years of rigorous imprisonment under Sections 452 and 376 IPC.
High Court Acquittal
However, on appeal, the Himachal Pradesh High Court overturned the conviction, citing multiple inconsistencies in the prosecution’s case, lack of credible evidence, and the complainant’s failure to fully cooperate with the investigation.
Supreme Court’s Observations & Reasoning
The Supreme Court carefully examined the evidence and upheld the High Court’s decision to acquit the accused.
1. Witness Testimonies Weakened the Prosecution Case
The Court noted that the mother of the prosecutrix (PW-9) did not support the prosecution’s case during her deposition in court. She outrightly denied any incident resembling the allegations in the FIR. Since her testimony contradicted the prosecution’s claims, she was declared a hostile witness.
Similarly, the father of the prosecutrix (PW-8) made vague and evasive statements and was unable to provide a satisfactory explanation for the delay in filing the FIR. The Court remarked that unexplained delays in lodging FIRs are often fatal to the prosecution’s case, and in this instance, there was not even an attempt to explain the delay.
2. Non-Cooperation with Medical Authorities
A key factor in the Court’s reasoning was that the prosecutrix and her parents did not fully cooperate with the medical examination process. The Supreme Court emphasized that refusal to undergo a medical examination in cases of sexual assault can raise serious doubts about the veracity of the allegations.
Quoting legal principles, the Bench reiterated:
“It is a well-settled proposition of law that non-allowance of medical examination by an alleged rape victim raises negative inferences against them. We cannot ascribe any good reason to the complete lack of assistance that the complainants tendered to the authorities, apart from their contradictory stances before the Court.”
3. Age of the Prosecutrix & Benefit of Doubt
The Court also noted that the prosecutrix was 19 years old at the time of the alleged incident and, being an adult, her actions and responses were crucial in evaluating the credibility of her testimony. Given the contradictions in her statements and her unwillingness to assist medical authorities, the Court found no compelling reason to interfere with the High Court’s acquittal.
4. Jurisdictional Limitations in Criminal Appeals
The Supreme Court emphasized that its interference in criminal appeals against acquittal is generally limited. It can only intervene when:
- The High Court’s findings are based on a complete misreading of evidence.
- The conclusions are so perverse that they cannot be sustained.
Since neither of these conditions were met in the present case, the Bench saw no reason to overturn the acquittal.
“The High Court had microscopically examined the entire evidence and firmly opined that the present accused-respondent deserved the benefit of the doubt,” the Bench observed.
Final Verdict: Supreme Court Dismisses Appeal
After reviewing the case in detail, the Supreme Court dismissed the appeal filed by the State of Himachal Pradesh, upholding the High Court’s judgment of acquittal in favor of Rajesh Kumar @ Munnu.
This ruling reinforces the principle that in cases of sexual assault, the victim’s cooperation with investigative and medical procedures is essential in establishing the veracity of allegations. While courts remain sensitive to the plight of victims, contradictions in witness testimonies and procedural lapses can significantly impact the outcome of a case.
- Case Title: The State of Himachal Pradesh v. Rajesh Kumar @ Munnu
- Neutral Citation: 2025 INSC 331
- Appellant’s Counsel: AOR Vikrant Narayan Vasudeva, Advocates Sarthak Chiller and Rohit Lochav
- Respondent’s Counsel: AOR Jogy Scaria, Advocates Beena Victor, M. Priya, and Ashwani Kumar Soni
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