The Supreme Court on Monday restored the conviction of two men for raping a minor girl, cautioning that frequent misapplication of the principle of beyond reasonable doubt was allowing actual culprits to escape punishment, undermining public faith in the criminal justice system.
A bench of Justices Sanjay Kumar and Satish Chandra Sharma said acquittals granted on the basis of minor contradictions and deficiencies in evidence amounted to a “misapplication” of the principle and often resulted in “loose acquittals” that embolden offenders while devastating victims.
“Every instance of acquittal of an actual culprit revolts against the sense of security of the society and acts as a blot on the criminal justice system,” the court observed.
The case arose in Bhojpur district, Bihar, where a minor girl became pregnant in 2016 after being raped by two accused. Following an FIR and investigation, the trial court convicted the men under charges of rape and provisions of the Protection of Children from Sexual Offences (POCSO) Act, sentencing them to life imprisonment.
However, in September 2024, the Patna High Court overturned the verdict, citing inconsistencies in the prosecution’s case and lapses in proof of the victim’s age. The victim’s father challenged the acquittal before the apex court.
The bench underscored that while no innocent person should face punishment, the flipside of overextending reasonable doubt is equally dangerous when guilty persons are acquitted due to trivial discrepancies.
The court said:
- On evidence: “There is nothing like perfect evidence in a court and in fact, perfection is often suggestive of tutoring and manufacturing of evidence.”
- On socio-economic context: Courts must remain sensitive to rural realities where discrepancies in school or identification documents are common and should not be fatal to a prosecution case.
- On appellate review: Trial courts lay the foundation “brick by brick.” While mistakes may occur, appellate courts must carefully assess whether such errors truly affect the outcome.
The court also called on trial courts to be vigilant in framing charges and not to let minor gaps in investigation dilute the pursuit of justice in cases of sexual offences against women and children.
Restoring the trial court’s conviction, the Supreme Court directed the two men to surrender within two weeks to serve their life sentence.
