Summary and Analysis of Deepak Kumar Sahu vs State of Chhattisgarh (2025 INSC 929)

1. Heading of the Judgment

Deepak Kumar Sahu vs State of Chhattisgarh
(Supreme Court of India, Criminal Appeal No. ______ of 2025)
Decided on: August 5, 2025
Judges: Hon’ble Justices Sudhanshu Dhulia and N.V. Anjaria

2. Related Laws and Sections

The case involves:

• Section 376(2) of the Indian Penal Code (IPC): Punishment for rape.

• Section 4 of the POCSO Act, 2012: Sexual assault against minors.

• Section 450 IPC: House-trespass to commit an offence punishable with life imprisonment.

3. Basic Case Details

• Accused: Deepak Kumar Sahu (Appellant).

• Incident Date: April 3, 2018 (around 12:00 noon).

• Victim: A 15-year-old girl.

• Prosecution Case:
  The victim and her 11-year-old brother were alone at home.
  The accused entered their house, sent the brother to buy tobacco, and raped the victim.
  The victim reported the incident to her cousin (Dushyantin) immediately. Parents were informed, and an FIR was lodged.

• Trial Court & High Court:
  Convicted the accused under Sections 376(2) IPC, Section 4 POCSO Act, and Section 450 IPC.
  Sentenced to 10 years rigorous imprisonment for rape, 5 years for house-trespass, and a fine.

• Appeal to Supreme Court: Challenged the conviction on three grounds:
  Unreliability of prosecutrix testimony due to lack of medical evidence.
  Contradictions between victim (PW-2) and brother (PW-9).
  Failure to prove the victim was a minor (to attract POCSO).

4. Explanation of the Supreme Court’s Judgment

A. Rejection of the Victim’s Minority Challenge

• Evidence of Age:
  Victim’s 8th-standard marksheet (DOB: October 9, 2002) proved she was 15 years 5 months old on the incident date.
  Corroborated by parents (PW-1 & PW-3) and the investigating officer (PW-18).

• Court’s View: POCSO Act was rightfully applied.

B. Reliability of Prosecutrix Testimony

• Medical Evidence Not Conclusive:
  No injury marks on the victim’s genitals (per doctors PW-11 & PW-17), but hymen was ruptured and healing.
  Court’s Ruling: Absence of injuries does not disprove rape. Medical evidence is not mandatory for conviction if the victim’s testimony is credible.

• Legal Precedents Cited:
  State of Punjab vs Gurmit Singh (1996): Absence of injuries does not imply consent.
  Lok Mal vs State of UP (2025): Injury marks are not necessary in every rape case.
  Wahid Khan vs State of MP (2010): Even slight penetration constitutes rape.

C. No Material Contradictions in Witness Testimony

• Victim (PW-2) and Brother (PW-9):
  Both consistently stated:
  Accused sent the brother to buy tobacco.
  Victim was gagged, forced onto a cot, and raped.
  Accused fled when the brother returned.

• Court’s View: Minor discrepancies (e.g., oral police questioning) were not fatal to the prosecution’s case.

• Precedents Cited:
  State of HP vs Lekh Raj (2001): Minor variations in testimonies are "hallmarks of truth".

D. Sole Testimony of Prosecutrix Suffices for Conviction

• Key Legal Principle:
  Conviction can be based solely on the victim’s testimony if it is credible, consistent, and inspires confidence. Corroboration is not mandatory.

• Precedents Reinforced:
  State of HP vs Manga Singh (2019): Corroboration is a "guidance of prudence", not a legal requirement.
  State of Maharashtra vs Chandraprakash Jain (1990): A rape victim is not an "accomplice" but a survivor; her testimony carries the same weight as an injured witness.

E. Societal Impact of Rape Acquittals

• Court’s Observation:
  Acquittals in sexual assault cases "encourage wolves in society" (State of Rajasthan vs N.K., 2000).
  Rape destroys the victim’s physical and psychological integrity (Gurmit Singh).

5. Final Outcome

• Supreme Court’s Decision:
  Appeal dismissed.
  Conviction and sentence (10 years for rape, 5 years for house-trespass) upheld.

• Reasoning Summary:
  "The prosecutrix’s testimony was clear, consistent, and trustworthy. Medical evidence is not indispensable when the victim’s account is reliable. Minor discrepancies do not weaken the prosecution’s case. The accused failed to prove false implication."

Key Takeaway: This judgment reinforces that in rape cases, the victim’s testimony alone can suffice for conviction if credible, and absence of injuries or minor witness contradictions cannot derail justice.