In a landmark decision, the Supreme Court of India has set aside the acquittal of an accused in a 1986 child rape case, reinstating the conviction originally recorded by the Sessions Court. The ruling comes nearly forty years after the incident, bringing long-delayed justice to the victim.
The case, State of Rajasthan v. Chatra (Criminal Appeal No. 586 of 2017), revolved around a brutal sexual assault on a minor girl, identified as ‘V’ in the judgment, in the village of Sureli, Rajasthan, on March 3, 1986. The accused, Chatra, had been convicted by the Sessions Court in 1987 but was acquitted by the Rajasthan High Court in 2013. The Supreme Court’s verdict reinstates the original conviction and directs the accused to surrender to authorities.
Background of the Case
On the night of March 3, 1986, Gulab Chand, a local resident, discovered ‘V’ unconscious and bleeding from her private parts inside the house of the accused, Chatra. Chand immediately filed a police report the next day. The prosecution presented substantial medical and eyewitness evidence, leading to Chatra’s conviction under Section 376 of the Indian Penal Code, 1860, by the Sessions Court in Tonk.
The Sessions Court sentenced Chatra to seven years of rigorous imprisonment, considering him a first-time offender aged 21 at the time of the crime. However, in 2013, the Rajasthan High Court overturned the conviction, citing inconsistencies in witness statements and a lack of conclusive forensic evidence. The acquittal was challenged by the State of Rajasthan in the Supreme Court.
Key Legal Issues
The Supreme Court’s decision addressed several crucial legal issues:
Credibility of Child Witnesses: The High Court had discredited ‘V’ for her silence during testimony. The Supreme Court ruled that trauma-induced silence should not be interpreted as a contradiction but rather as a psychological consequence of sexual violence against children.
Delay in Filing the FIR: The High Court questioned why the FIR was lodged a day after the incident. The Supreme Court deemed the delay reasonable, considering the rural setting and the victim’s critical medical condition.
Reliability of Medical Evidence: The Supreme Court found that the medical examination corroborated the prosecution’s case. The doctor had testified that the injuries were consistent with forced sexual assault and could not have resulted from an accident.
Treatment of Eyewitness Testimony: The High Court dismissed the testimony of key eyewitness Gulab Chand due to minor discrepancies between his initial police report and courtroom deposition. The Supreme Court ruled that such variations were natural and did not undermine his credibility.
Supreme Court’s Observations & Ruling
The bench, comprising Justices Vikram Nath and Sanjay Karol, expressed dismay at the High Court’s handling of the case, noting that the judgment lacked a detailed assessment of the evidence. The court made several significant observations:
“Tears of the child cannot be ignored. Trauma has engulfed her in silence, and it would be unfair to burden her young shoulders with the weight of the entire prosecution.”
“The High Court’s failure to independently assess the evidence before setting aside the conviction is a grave oversight.”
“Circumstantial evidence and medical reports, when combined with reliable eyewitness testimony, form a chain of evidence too strong to be broken by minor inconsistencies.”
The Supreme Court held that the prosecution had established the accused’s guilt beyond reasonable doubt. Restoring the conviction, the court directed Chatra to surrender within four weeks to serve his remaining sentence, if not already completed.
