Supreme Court of India

Mukesh v. State of NCT of Delhi

Criminal Appeal Nos. 607-608 of 2017 [AIR 2017 SC 2161]

Ratio Decidendi

Conviction for rape can be based on the sole testimony of the victim and the same does not require corroboration, provided that the testimony is natural and trustworthy. The Court must look at the broad probabilities, not discard the testimony due to minor contradictions which are not substantial in character given that they are usually hallmarks of truth of the testimony. Further, due to the efflux of time, it is natural for there to be minor discrepancies / contradictions in the testimony. There is no need for corroboration till the testimony does not suffer from serious infirmities.

Case Notes

Facts

The victim was a 23 year old girl who was gangraped, sodomised, assaulted with an iron rod and thrown out of a moving bus. The accused was convicted by the Trial Court and awarded the death penalty. The same was affirmed by the High Court. An appeal was then filed by the accused persons before the Supreme Court appealing the conviction on various grounds including that improvements were made in the victims statements/dying declarations.


Judgment

The Supreme Court stressed on the need for courts to approach rape cases with utmost sensitivity, examine broader probabilities and not get side tracked by minor contradictions. The Court reiterated the well settled principle that conviction for rape could be based on the sole testimony of the prosecutrix corroborated by medical evidence and other circumstantial evidence such as reports of chemical examination, scientific examination,etc., if found natural and trustworthy. But the Court also emphasised that there was no legal compulsion to look for corroboration unless the testimony suffered from serious infirmities. Corroboration was only a guidance of prudence under certain circumstances. The Court noted that minor variations in the testimony of the victim were often a hallmark of truth of the testimony. The Court also observed that due to the efflux of time, the prosecutrix’s testimony were bound to have minor contradictions/discrepancies. The court upheld the conviction and the death penalty awarded to the accused persons.