Conviction Cannot Rest on a Prosecutrix’s Testimony Marred by Material Inconsistencies: Punjab and Haryana High Court Extends Benefit of Doubt and Acquits Accused in Sexual Assault Appeal

Case Title: X v. State of Punjab

Date of Judgment: 22 July 2026

Citation: CRA-S-1956-SB-2004

Bench: Hon’ble Ms. Justice Rupinderjit Chahal

Held: The Punjab and Haryana High Court held that although the testimony of a prosecutrix can, by itself, sustain a conviction for rape if it is wholly reliable and of sterling quality, such testimony must withstand careful judicial scrutiny and inspire complete confidence. Where the prosecution version suffers from material inconsistencies, unexplained omissions and objective circumstances creating reasonable doubt, conviction cannot be sustained merely on the basis of the prosecutrix’s statement.

The Court found that the prosecution failed to establish guilt beyond reasonable doubt as the medical evidence did not support the allegation of a violent physical struggle, the investigation failed to corroborate the alleged scene of occurrence, a material eyewitness cited by the prosecution was withheld without justification, there were significant inconsistencies regarding the investigation timeline, and the delay in lodging the FIR remained unexplained in the factual matrix of the case. Consequently, extending the benefit of doubt, the Court set aside the conviction and acquitted the appellant.

Summary: The appeal challenged the judgment of conviction and sentence whereby the appellant had been convicted under Section 376 of the Indian Penal Code and sentenced to undergo seven years’ rigorous imprisonment.

The prosecution alleged that the prosecutrix was subjected to forcible sexual intercourse while she had gone to agricultural fields. Following investigation, the trial court convicted the accused principally relying upon the testimony of the prosecutrix.

Before the High Court, the appellant argued that the conviction was unsustainable because the prosecution story suffered from serious infirmities. It was contended that despite allegations of a violent struggle, the medico-legal examination revealed no external or internal injuries. The defence further highlighted that the prosecution itself had projected an independent eyewitness to the occurrence but failed to examine him during trial. It was also pointed out that the investigating officer did not notice any physical signs consistent with the alleged struggle at the place of occurrence, while contradictions regarding the police visit prior to registration of the FIR and the unexplained delay in lodging the FIR further weakened the prosecution case.

After examining the evidence, the High Court reiterated that the sole testimony of a prosecutrix can undoubtedly form the basis of conviction if it is natural, trustworthy and of sterling quality. However, the Court observed that where the prosecution itself alleges active physical resistance, the absence of corresponding medical and objective evidence assumes considerable significance. The Court found that the prosecution version was not corroborated by the surrounding circumstances and that the cumulative effect of the inconsistencies created reasonable doubt regarding its reliability.

The Court also drew an adverse inference against the prosecution for withholding the independent eyewitness whom it had itself described as a natural witness to the occurrence. Additionally, the contradiction concerning the police allegedly visiting the place of occurrence before registration of the FIR, coupled with the unexplained delay in reporting the incident, further undermined the prosecution case.

While reaffirming the settled principle that corroboration is not a mandatory requirement in every sexual offence prosecution, the Court held that where the testimony of the prosecutrix is not free from material infirmities and fails to inspire confidence, it would be unsafe to sustain a conviction solely on that basis. Applying the settled principle that every reasonable doubt must enure to the benefit of the accused, the Court concluded that the prosecution had failed to prove the charge beyond reasonable doubt.

Decision: The High Court allowed the criminal appeal, set aside the judgment of conviction and the order of sentence passed by the Trial Court, acquitted the appellant of all charges by extending the benefit of doubt, and discharged the bail and surety bonds.