Sole testimony of the prosecutrix is sufficient for conviction in rape cases: Supreme Court

Introduction

The Supreme Court of India, in the case of Lok Mal @ Loku v. State of Uttar Pradesh (2025 INSC 344), reaffirmed the principles governing the appreciation of evidence in rape cases. The judgment, authored by Justice Prasanna B. Varale, dismissed the appeal filed by the accused and upheld the conviction under Sections 376 and 323 of the Indian Penal Code (IPC). The case reiterates the settled legal principle that the testimony of a prosecutrix, if found credible, can be the sole basis for conviction.

Brief Facts of the Case

On 19th March 1984, the prosecutrix, a college student, visited the residence of the accused to provide tuition to two girls. During her visit, the accused allegedly took advantage of her vulnerability, forcibly confined her in a room, gagged her mouth, and committed rape. The prosecutrix attempted to resist, but the accused overpowered her. After the incident, threats from the accused and his family initially deterred the victim and her relatives from approaching the police. However, a complaint was eventually lodged, leading to the registration of an FIR under Sections 376, 323, 504, and 506 of IPC.

The trial court convicted the accused under Sections 376 and 323 IPC and sentenced him to rigorous imprisonment for five years and six months, respectively. The High Court of Allahabad, while dismissing the appeal, upheld the trial court’s decision but acquitted him under Section 506 IPC. The accused, aggrieved by this verdict, filed an appeal before the Supreme Court.

Contentions of the Parties

Appellant’s Arguments:

1. The prosecution’s case relied solely on the testimony of the prosecutrix, which, according to the defense, was unreliable due to lack of corroboration.
2. There was an inordinate delay in filing the FIR, raising doubts about the authenticity of the allegations.
3. The medical evidence did not indicate any injuries to the prosecutrix’s private parts, suggesting that the incident did not occur as alleged.
4. The prosecutrix’s mother had a questionable reputation, and the case was a result of personal enmity.

State’s Arguments:

1. The prosecution argued that the testimony of the prosecutrix was consistent and unshaken, which is sufficient for conviction.
2. The absence of injuries does not necessarily negate the occurrence of rape, as force can be exerted without leaving visible marks.
3. The delay in lodging the FIR was justified as the prosecutrix was under duress due to the threats posed by the accused and his family.
4. The accused failed to provide any substantive evidence to support his claim of false implication.

Supreme Court’s Observations and Decision

1. Credibility of the Prosecutrix’s Testimony:
   • The Court reaffirmed that in cases of sexual assault, the victim’s testimony holds the same evidentiary value as that of an injured witness. Relying on State of Punjab v. Gurmit Singh (1996) and Bharwada Bhoginbhai Hirjibhai v. State of Gujarat (1983), the Court held that minor inconsistencies should not undermine the testimony of a rape survivor.
   • The prosecutrix’s account remained unshaken during cross-examination, demonstrating its reliability.
2. Medical Evidence:
   • The Court rejected the argument that the absence of injuries in the medical report discredited the prosecutrix’s allegations. It emphasized that lack of physical injuries does not imply consent or negate the occurrence of rape, as per settled precedents.
3. Delay in Filing FIR:
   • The Court found that the prosecutrix’s hesitation in reporting the crime was justified due to the threats and societal stigma attached to such cases.
4. Character Assassination of the Victim’s Mother:
   • The Court dismissed the appellant’s attempt to malign the character of the prosecutrix’s mother, stating that such allegations have no bearing on the guilt or innocence of the accused.

Conclusion

The Supreme Court’s judgment in Lok Mal @ Loku v. State of Uttar Pradesh reaffirms the fundamental legal position that the sole testimony of the prosecutrix, if credible and trustworthy, is sufficient for conviction in rape cases. It underscores that delay in filing FIR and the absence of injuries cannot be decisive factors in negating allegations of sexual assault. The Court’s refusal to entertain character assassination of the prosecutrix’s family further strengthens the legal protection afforded to survivors of sexual violence.

By dismissing the appeal, the Supreme Court upheld the conviction, reinforcing the commitment of the judiciary to ensuring justice for victims of sexual offenses. The decision serves as a significant precedent in reaffirming the principles governing the appreciation of evidence in cases of sexual violence.

References

1. Lok Mal @ Loku v. State of Uttar Pradesh, 2025 INSC 344.
2. State of Punjab v. Gurmit Singh, (1996) 2 SCC 384.
3. Bharwada Bhoginbhai Hirjibhai v. State of Gujarat, (1983) 3 SCC 217.