Introduction:

In the case titled Deepak Kumar Sahu versus State of Chhattisgarh, bearing citation 2025 LiveLaw (SC) 776, the Supreme Court of India, through a bench comprising Justices Sudhanshu Dhulia and NV Anjaria, upheld the conviction of the appellant Deepak Kumar Sahu for sexually assaulting a 15-year-old girl. The Court affirmed the Chhattisgarh High Court’s decision which had earlier confirmed the trial court’s ruling, sentencing the appellant to rigorous imprisonment for ten years under Section 376(2) of the Indian Penal Code and Section 4 of the Protection of Children from Sexual Offences Act, 2012 (POCSO Act), along with a fine of ₹1,000. Represented by Mr. Manish Kumar Saran (AOR), along with advocates Ms. Ananya Tyagi and Mr. Sidhant Sharma, the petitioner contested the verdict on grounds primarily revolving around the absence of emphatic medical evidence indicating forced sexual intercourse, and the lack of external injuries on the body of the victim. The respondent, notably, did not enter appearance. The central plank of the appellant’s argument was that the absence of corroborative medical findings, especially the lack of injury marks or physical trauma on the private parts of the minor girl, seriously undermined the prosecution’s narrative. He attempted to portray this medical silence as a fundamental flaw in the prosecution’s case, and that such evidentiary gaps were sufficient to generate doubt over the occurrence of the offence.

Arguments:

The appellant asserted that in the absence of any direct eyewitness and tangible forensic evidence, the sole reliance on the victim’s testimony was legally insufficient to sustain his conviction. Moreover, he argued that the inconsistencies or lack of detailed medical records regarding penetration, physical resistance, or struggle should have cast a shadow of reasonable doubt. However, the prosecution forcefully rebutted these claims by drawing the Court’s attention to the consistent, cogent, and credible account given by the prosecutrix throughout the investigation and trial proceedings. It was emphasized that the victim, despite her young age, exhibited clarity, naturalness, and reliability in narrating the sequence of events. Her testimony had been unwavering and stood firm even under the duress of cross-examination.

The prosecution further argued that Indian criminal jurisprudence, particularly in sexual assault cases, does not demand corroborative medical evidence if the testimony of the victim is found to be trustworthy and credible. In backing this stance, reliance was placed on settled legal precedents which have consistently held that the sole testimony of the victim, if found cogent, can form the basis for conviction, especially in cases involving sexual offences. It was also pointed out that many instances of rape may not necessarily leave behind visible marks of injury, particularly when the victim is too young, scared to resist, or frozen by trauma.

Judgement:

The Court, in a detailed and well-reasoned judgment authored by Justice NV Anjaria, found merit in the prosecution’s case and dismissed the appellant’s contentions. The bench strongly reaffirmed that the absence of medical evidence or external injuries is not a sufficient reason to disbelieve the consistent testimony of the victim. The Court referred to its earlier judgment in Wahid Khan vs. State of Madhya Pradesh, (2010) 2 SCC 9, where it had been held that even the slightest penetration suffices to establish the offence of rape under the law. The judges made it unequivocally clear that Section 375 of the IPC does not require violent resistance or physical injuries as preconditions for conviction. They underscored the legal principle that the Indian Evidence Act does not demand corroboration of the victim’s testimony by medical reports for a conviction to be upheld. The Court emphasized that the testimony of the victim, when natural, probable, and trustworthy, must be given significant evidentiary weight. In this case, the victim’s account was not only consistent but was also supported by circumstantial details, including the testimony of her younger brother Mayank, who was treated as a child witness. His statement corroborated key aspects of the victim’s account, especially regarding the location and context of the offence. The Court noted that his version, though that of a child, was logical, coherent, and free from coaching or fabrication. Further, the presence of a cot in the porch, as narrated by the prosecutrix, was also substantiated by other supporting evidence. The bench held that these surrounding facts lent further credence to the victim’s narrative. Refusing to entertain the appellant’s argument about the absence of injuries, the Court stated that many victims, especially minors, do not resist due to fear, trauma, or overpowering by the accused, and hence, lack of injuries cannot automatically negate the occurrence of the offence. The Court also rejected the implied suggestion that the victim could have falsely implicated the appellant. It stated that there existed no compelling reason or motive for a 15-year-old girl to level such a serious allegation against the appellant falsely. Her conduct was found to be consistent with someone who had suffered a traumatic sexual assault. Justice Anjaria wrote that her evidence was “entirely probable, natural and trustworthy,” and reiterated that courts must adopt a sensitive and realistic approach while evaluating the evidence of victims of sexual crimes. The Court observed that it has become a well-established position in Indian criminal law that the testimony of the prosecutrix stands on par with that of an injured witness. While medical evidence is undoubtedly important, it is not conclusive or indispensable. If the testimony of the prosecutrix inspires confidence, the Court should not hesitate to act upon it. Moreover, the Court highlighted that the absence of a vaginal swab or the failure to retrieve DNA samples should not be treated as fatal flaws in the prosecution’s case, especially when the delay in lodging the FIR was reasonable, and the integrity of the victim’s version remained intact throughout the trial. Upholding the concurrent findings of the trial court and the High Court, the Supreme Court ruled that the appellant had failed to show any legal infirmity or perversity in the judgments that would warrant interference. The sentence of ten years rigorous imprisonment under the relevant sections was also confirmed. In conclusion, the Supreme Court reiterated the legal position that in prosecutions under POCSO and rape laws, the courts must prioritize the victim’s testimony, and not insist on unrealistic standards of corroboration, particularly medical corroboration, which may not always be present or possible. The decision serves as another landmark reaffirmation of the judiciary’s evolving victim-centric approach in sexual offence cases. By giving primacy to the voice of the victim and recognizing the psychological realities of trauma, the Court underscored that justice in such cases must not be derailed due to procedural or evidentiary technicalities. The Court’s reiteration of the principle that a credible victim’s account, in itself, is sufficient to convict, also sends a strong message to trial courts to avoid unnecessary reliance on corroboration, especially where the victim’s testimony is consistent, rational, and emotionally coherent. With this ruling, the Court also indirectly reinforced the constitutional mandate of protecting children from sexual exploitation and ensuring that procedural formalities do not result in denial of justice. The verdict further aligns with the objectives of the POCSO Act which mandates child-friendly procedures and prioritizes the best interest of the child throughout the trial process.