Deepak Kumar Sahu vs State of Chhattisgarh 2025 INSC 929 - Rape Case - Sole Testimony Of Victim
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Indian Penal Code 1860 - Section 376 - In cases of offences committed under Section 376, IPC, when the story of the victim girl as told in the evidence is found credit-worthy, the apparent insufficiency of medical evidence pitted against acceptable testimony of the victim, the latter would prevail- The credible and reliable evidence of prosecutrix could not be jettisoned for want of corroboration including the corroboration by medical report or evidence. [Context: While upholding rape conviction, SC observed: Merely because the medical evidence was less corroborative and less supportive or absent in details or indictive of no external injuries. It in no way weakened the prosecution case. Sole testimony of the victim was a strong evidence to rely on along with available attendant evidence]
Case Info
Case Name and Neutral Citation
- Case Name: Deepak Kumar Sahu vs. State of Chhattisgarh
- Neutral Citation: 2025 INSC 929
Coram (Judges)
- Justice Sudhanshu Dhulia
- Justice N.V. Anjaria
Judgment Date
- Date: August 5, 2025
Caselaws and Citations Referred
- State of Punjab vs. Gurmit SinghCitation: (1996) 2 SCC 384
- State of Himachal Pradesh vs. Manga SinghCitation: (2019) 16 SCC 759
- Lok Mal alias Loku vs. State of Uttar PradeshCitation: (2025) 4 SCC 470
- Wahid Khan vs. State of Madhya PradeshCitation: (2010) 2 SCC 9
- Raju alias Umakant vs. State of Madhya PradeshCitation: (2025 SCC OnLine SC 997)
- State of Rajasthan v. N.K. the AccusedCitation: (2000) 5 SCC 30
- Rameshwar v. State of RajasthanCitation: 1951 SCC 1213
- State of Maharashtra v. Chandraprakash Kewal Chand JainCitation: (1990) 1 SCC 550
- Bharwada Bhoginbhai Hirjibhai vs. State of GujaratCitation: (1983) 3 SCC 217
- State of Himachal Pradesh vs. Lekh RajCitation: (2001) 1 SCC 247
- Ousu Varghese vs. State of KeralaCitation: (1974) 3 SCC 767
- Jagdish vs. State of Madhya PradeshCitation: (1981) SCC (Crl.) 676
Statutes/Laws Referred
- Indian Penal Code, 1860 (IPC)
- Section 450
- Section 376(2)
- Section 375 (definition of rape)
- Protection of Children from Sexual Offences Act, 2012 (POCSO Act)
- Section 4
- Code of Criminal Procedure, 1973
- Section 164
- Indian Evidence Act, 1872
- Section 114 (illustration (b) referenced in context)
#SupremeCourt reiterates that sole testimony of rape victim, when reliable, can be the basis for conviction. https://t.co/aRWKugmB05 pic.twitter.com/vSPpYJDWUu
— CiteCase 🇮🇳 (@CiteCase) August 6, 2025
