Meghalaya High Court Rules Sole Testimony of Rape Victim Sufficient for Conviction

In a landmark decision, the Meghalaya High Court has ruled that the sole testimony of a rape victim, if of sterling quality, is sufficient to convict the accused. This ruling emphasizes the importance of the victim’s credibility and reliability in such cases, even in the absence of corroborative medical evidence.

Key Takeaways

The Meghalaya High Court convicted an accused based on the sole testimony of a minor rape victim.
The court found the victim’s testimony to be reliable and credible, requiring no corroboration.
The accused was initially sentenced to 25 years of rigorous imprisonment, later reduced to 10 years due to legal technicalities.
The ruling aligns with the Supreme Court’s stance on the importance of the victim’s testimony in rape cases.

Meghalaya High Court’s Landmark Decision

The Meghalaya High Court recently convicted an accused for raping a minor based solely on the victim’s testimony. The court found the victim’s statement to be of sterling quality, meaning it was reliable and credible enough to convict the accused without needing corroborative medical evidence. The bench, comprising Chief Justice S. Vaidyanathan and Justice W. Diengdoh, referenced the Supreme Court’s case of Ganesan vs. State to support their decision.

“The statement made by the victim girl appears to be very innocent in nature and she was actually not aware about what was the wrong done to her by the accused persons. She was playing as usual with the pain in her buttocks and when her mother asked her as to why she was unable sit in a correct position, out of unbearable pain and intolerability, she had disclosed the act of the accused to her mother, which, in our considered view, was not a tutored one and was of sterling quality, so as to inspire confidence in the minds of this Court,” the High Court said.

Legal Technicalities and Sentence Reduction

Initially, the accused was sentenced to 25 years of rigorous imprisonment under Section 376 IPC read with Section 6 of the POCSO Act, 2012. However, the court later reduced the sentence to 10 years, citing that the punishment under the amended Section 376 IPC could not be applied retrospectively. The court found that the trial court had erred in imposing a 25-year sentence, as the offense was committed before the 2013 Criminal Law Amendment.

Supreme Court’s Stance on Victim’s Testimony

The Supreme Court has also weighed in on the importance of the victim’s testimony in rape cases. In the case of Santosh Prasad @ Santosh Kumar vs. The State of Bihar, the Supreme Court held that the sole testimony of the prosecutrix could be sufficient for conviction if it is of sterling quality. The court emphasized that the testimony must be absolutely trustworthy, unblemished, and of high quality.

Jammu and Kashmir High Court’s Perspective

Similarly, the Jammu and Kashmir and Ladakh High Court has ruled that before relying solely on the testimony of the prosecutrix, the court must ensure that her statement leaves no room for doubt and aligns with other supporting evidence. The court stressed that the prosecutrix’s version must withstand cross-examination and be free of contradictions.

Conclusion

The Meghalaya High Court’s ruling underscores the significance of the victim’s testimony in rape cases, provided it is of sterling quality. This decision aligns with the broader judicial perspective that emphasizes the credibility and reliability of the victim’s statement, even in the absence of corroborative evidence.