The Supreme Court emphasized that in rape cases, a conviction can be sustained solely on the testimony of a single witness, including the victim, provided that the evidence instills confidence in the Court.

While mentioning the significant weight given to a victim's statement, the Court stressed the importance of thoroughly scrutinizing it.

“Although it is absolutely true that in the case of rape, conviction can be made on the sole testimony of the prosecutrix as her evidence is in the nature of an injured witness which is given a very high value by the Courts. But nevertheless when a person can be convicted on the testimony of a single witness the Courts are bound to be very careful in examining such a witness and thus the testimony of such a witness must inspire confidence of the Court.,” observed the Bench of Justices Sudhanshu Dhulia and Prashant Kumar Mishra.

The prosecution alleged that the accused intercepted the victim on her way back from school, grabbed her hand, and threatened her by placing a knife on her back. He then took her to a nearby grocery shop, where he forced physical relations with her. Consequently, the accused was charged under the Indian Penal Code and the Protection of Children from Sexual Offences (POCSO) Act.

However, the Trial Court acquitted the accused, concluding that the prosecution had failed to establish its case beyond a reasonable doubt. This decision was subsequently upheld by the High Court, leading to the present appeal.

The Apex Court noted that the victim's testimony was primarily presented before the Trial Court. It then referenced the medical examination, which revealed no injuries on the victim's body. Additionally, the Court highlighted inconsistencies in her statement. For example, the victim claimed to have struck the accused, yet no injuries were found on his body when he surrendered.

“Definitely the prosecutrix in her examination-in-chief as well as in cross-examination has stuck to the fact that she was raped by the accused but the fact remains that she has contradicted her statement at more than one place.''

''Moreover she has said in her statement under Section 164 CrPC she had hit the accused on her head by Danda whereas in her examination-in-chief she stated that she hit the accused on his foot. When the accused had surrendered on 10.10.2014 none of these injuries were noticed on the body of the accused.”''

The Court further expressed skepticism regarding the victim's actions, finding it implausible that she accompanied the accused without raising any alarm or attempting to seek help.

“It is not believable that when the prosecutrix was caught by the accused who is known to the prosecutrix, she went with him quite a distance in the Bazaar and then to a shop, she never raised any alarm. The only reason she gave is that there was a knife with accused and he had threatened her that if she raises an alarm her brother and father would be killed.”

Based on these circumstances, the Court concluded that her statement did not inspire confidence. It thus refused to interfere with the impugned orders and dismissed the present appeal.

Case Name: STATE (GNCT OF DELHI) v. VIPIN @ LALLA