Supreme Court Acquits Doctor in Rape Case; Holds Conviction Cannot Rest on FIR and Investigating Officer Testimony When Victim and Key Witnesses Turn Hostile

Case Name: Jayantibhai Chaturbhai Patel v. State of Gujarat
Citation: 2025 INSC 1443
Date of Judgment/Order: 16 December 2025
Bench: Sanjay Karol, J.; Vipul M. Pancholi, J.

Held: The Supreme Court held that where the victim and her husband, who were the principal witnesses, did not support the prosecution case and were declared hostile, and where medical and forensic evidence failed to corroborate the allegation of rape, the courts below committed a serious error in sustaining the conviction by presuming that the witnesses had been “won over” and by relying predominantly on the FIR, recovery panchnamas, FSL reports, and the testimony of the investigating officer, as such material cannot substitute proof beyond reasonable doubt during trial.

Summary: The appellant, a medical practitioner, was accused of committing rape on a female patient during medical examination in his clinic in 2001 and was convicted by the Trial Court under Section 376(2)(d) IPC, receiving a sentence of six years’ rigorous imprisonment, which was later enhanced by the Gujarat High Court to ten years on the State’s appeal. During trial, however, the prosecutrix and her husband did not support the prosecution version and were declared hostile, and several independent witnesses cited by the prosecution were not examined. The High Court nonetheless affirmed conviction on the premise that the witnesses had been won over and relied on recovery of clothes and FSL reports. The Supreme Court closely scrutinised the evidence and found that the panch witnesses to the recovery panchnamas had themselves turned hostile, the medical evidence did not indicate recent sexual intercourse, semen samples were not conclusively proved, and no independent witness present at the clinic was examined. The Court reiterated settled law that while hostile witness testimony is not to be rejected outright, courts must exercise great caution and ordinarily seek corroboration, and that allegations in an FIR or statements proved indirectly through the investigating officer cannot by themselves form the basis of conviction.

Decision: The Supreme Court allowed the appeals, set aside the judgment of conviction and sentence passed by the Trial Court as well as the common judgment of the Gujarat High Court enhancing the sentence, acquitted the appellant of the offence under Section 376 IPC, and discharged his bail bonds, holding that the prosecution had failed to establish guilt beyond reasonable doubt.