False Rape Allegation Overturned: Supreme Court Acquits Two Men in Odisha Case

The Supreme Court of India, in the case of Dola @ Dolagobinda Pradhan & Another v. The State of Odisha, overturned the conviction of two men accused of rape, citing inconsistencies in the prosecution’s case. The judgment, delivered on August 29, 2018, by a bench comprising Justice N.V. Ramana and Justice Mohan M. Shantanagoudar, emphasized that in the absence of credible evidence, the accused could not be held guilty beyond a reasonable doubt.

Background of the Case

The case stemmed from an alleged rape incident that occurred on March 24, 1990. The victim, a woman running a roadside eatery near Khuntagaon weekly market in Odisha, claimed that while returning home at around 8:00 p.m., she was forcibly taken to a nearby date-palm grove by two men, Dola @ Dolagobinda Pradhan and Akshya Pradhan. She alleged that they gagged her mouth with a napkin, threatened her with a knife, and raped her.

The following day, she lodged a First Information Report (FIR) at the local police station. The police conducted an investigation and filed a charge sheet against both accused under Section 376(2)(g) of the Indian Penal Code (gang rape). The trial court convicted the accused, sentencing them to 10 years of rigorous imprisonment. The Odisha High Court upheld this conviction. The accused then filed an appeal before the Supreme Court.

Petitioners’ (Accused) Arguments

The defense, representing Dola @ Dolagobinda Pradhan and Akshya Pradhan, argued the following:

• The prosecution’s case relied solely on the uncorroborated testimony of the victim, which was insufficient for conviction.
• The medical evidence did not support the claim of rape—there were no signs of recent sexual intercourse or injuries on the victim.
• The accused were falsely implicated due to a pre-existing business rivalry.
• The victim’s husband, a key witness, did not support her allegations in court.
• The police failed to recover the alleged knife used in the crime or any other substantial evidence.

Respondent’s (Prosecution’s) Arguments

The state, defending the conviction, contended that:

• The victim’s testimony was sufficient to establish the crime, as she had no reason to falsely implicate the accused.
• Medical evidence did not completely rule out sexual assault.
• Eyewitness accounts were not always necessary in rape cases, particularly when threats were involved.
• The accused had prior disputes with the victim and her husband, providing them with a motive.

Supreme Court’s Observations

After reviewing the evidence, the Supreme Court identified several flaws in the prosecution’s case:

• The medical report found no conclusive evidence of rape, such as injuries on the victim’s body or seminal stains on her clothing.
• The victim admitted that she had not clearly seen the faces of the accused during the alleged assault and recognized them only by their voices, which was unreliable.
• The scene of the alleged crime was a busy area near a weekly market, making it unlikely that a crime of this nature could occur unnoticed.
• The victim’s husband, who was expected to support her allegations, turned hostile and denied any knowledge of the rape.
• The prosecution failed to recover any forensic evidence linking the accused to the crime.

Final Judgment

The Supreme Court ruled that the conviction was based on weak evidence and could not be sustained. The Court held:

• The inconsistencies in the victim’s testimony created reasonable doubt regarding the allegations.
• Medical and forensic evidence did not corroborate the rape charge.
• Since the prosecution had failed to prove the guilt of the accused beyond a reasonable doubt, the benefit of doubt must be given to the accused.
• The conviction and sentence imposed by the trial court and upheld by the High Court were set aside.
• The accused were acquitted and ordered to be released immediately.

Impact of the Judgment

The Supreme Court’s ruling reinforced several legal principles:

• Burden of Proof: The prosecution must establish guilt beyond a reasonable doubt, even in sensitive cases.
• Uncorroborated Testimony: A rape victim’s testimony must be credible, consistent, and backed by medical or circumstantial evidence.
• False Implications: The judgment recognized the possibility of false accusations arising from personal disputes.
• Judicial Oversight: The decision emphasized that courts must scrutinize evidence thoroughly to prevent wrongful convictions.

Conclusion

The Supreme Court’s verdict in Dola @ Dolagobinda Pradhan & Another v. The State of Odisha is a crucial reminder that justice must be based on reliable evidence. While it is important to protect victims of sexual assault, it is equally critical to ensure that individuals are not convicted based on unverified claims. The ruling underscores the judiciary’s role in balancing the rights of the accused with the need to punish actual offenders, reinforcing the principle that no person should be convicted unless their guilt is established beyond a reasonable doubt.

Petitioner Name: Dola @ Dolagobinda Pradhan & Another.
Respondent Name: The State of Odisha.
Judgment By: Justice N.V. Ramana, Justice Mohan M. Shantanagoudar.
Place Of Incident: Odisha.
Judgment Date: 29-08-2018.

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