Convicting Someone By Holding Rape Victim’s Statement To Be Gospel Truth Would Be Travesty Of Justice: Punjab and...
Principle: Cautious Approach to Victim’s Statement in Rape Cases
The statement of a rape victim is an important piece of evidence but cannot be accepted blindly as the absolute truth.
Courts must scrutinize the evidence holistically and apply the doctrine of prudence before convicting.
Mere acceptance of the victim’s testimony as gospel truth without corroboration or examination of circumstances can lead to miscarriage of justice.
However, disbelief or undervaluation of the victim’s evidence on mere suspicion is equally wrong.
Why This Principle Exists
Trauma and Repression
Victims may have memory lapses or inconsistent narrations due to trauma.
False Allegations
While rare, false accusations can occur; thus, judicial caution is necessary.
Standard of Proof
Criminal conviction requires proof beyond reasonable doubt.
Balancing Justice
Protecting the accused from wrongful conviction while ensuring victims get justice.
Guidelines for Courts
The victim’s testimony must be carefully examined in light of:
Medical evidence
Circumstances of the case
Presence or absence of corroborative evidence
Delay in lodging complaint
Courts must assess consistency and reliability, not merely accept statements at face value.
The principle of “gospel truth” does not mean uncritical acceptance but due weight to the victim’s testimony.
Key Case Laws
1. State of Punjab v. Gurmit Singh, (1996) 2 SCC 384
The Supreme Court held that courts should be careful not to convict a person solely on the basis of the victim’s testimony without corroboration if other evidence is missing or contradictory.
The victim’s statement should be subjected to careful scrutiny.
2. State of Rajasthan v. Om Prakash, (1994) 4 SCC 595
It was observed that mere acceptance of the victim’s statement as gospel truth without corroboration or inquiry can lead to injustice.
The victim’s credibility and circumstances must be tested.
3. Dalbir Singh v. State of Punjab, (1999) 3 SCC 192
The Court stated that it is a travesty of justice to convict solely on the statement of the prosecutrix without careful evaluation.
Corroborative evidence is not always necessary, but reasons for reliance on the sole testimony must be clearly recorded.
4. Raju @ Rajesh v. State of Karnataka, (2019) 10 SCC 526
The Court reiterated that the victim’s testimony must be examined with caution, and inconsistencies or improbabilities cannot be ignored.
The prosecution must prove the charge beyond reasonable doubt.
5. Punjab and Haryana High Court – Ruling Emphasizing Prudence
The High Court has held repeatedly that courts must avoid mechanical acceptance of victim’s statement as gospel truth.
The statement should be corroborated or at least consistent and credible.
Summary
The statement of a rape victim is crucial but not automatically conclusive.
Courts must apply the doctrine of prudence—examine, scrutinize, and weigh all evidence before convicting.
Conviction based solely on uncritical acceptance of victim’s testimony can lead to miscarriage of justice.
The approach balances protecting victims and ensuring fairness to the accused.
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