Supreme Court Holds Conviction Cannot Rest on Unreliable Sole Testimony of Prosecutrix with Unexplained Delay and Material Contradictions
Case Name: Rajendra and Others v. State of Uttarakhand
Citation: 2026 INSC 238
Date of Judgment/Order: 13 March 2026
Bench: Hon’ble Mr. Justice Pankaj Mithal; Hon’ble Mr. Justice Prasanna B. Varale
Held: The Supreme Court held that while conviction can be based on the sole testimony of the prosecutrix, such testimony must inspire confidence; where there is unexplained delay in lodging FIR, material contradictions, absence of corroborative evidence, and surrounding circumstances creating doubt, conviction cannot be sustained and benefit of doubt must be given to the accused.
Summary: The case arose from a conviction of the appellants under Section 376(2)(g) IPC and Section 506 IPC based primarily on the testimony of the prosecutrix. The FIR was lodged after a delay of over three months, with explanations that were found inconsistent and unnatural. The prosecutrix claimed fear and shame prevented earlier reporting, yet she did not disclose the incident to her family but to an unidentified woman who was never examined. The Court noted significant inconsistencies between the FIR and statements under Section 164 CrPC regarding the place and manner of occurrence. Further, the prosecution failed to produce key witnesses and relied solely on the testimony of the prosecutrix without medical or corroborative evidence. The defence of prior enmity was also not adequately considered by the courts below. The Supreme Court emphasized that though sole testimony can suffice, it must be credible and trustworthy; in the present case, the version failed to inspire confidence due to contradictions, delay, and lack of supporting evidence.
Decision: The Supreme Court allowed the appeal, set aside the conviction and sentence imposed by the Trial Court and affirmed by the High Court, and directed that the appellants be released forthwith if not required in any other case, while disposing of all pending applications.