Supreme Court Upholds Acquittal in Himachal Pradesh Rape Case Citing Contradictions in Evidence

The Supreme Court of India recently delivered a significant judgment upholding the acquittal of two accused persons in a high-profile rape and kidnapping case from Himachal Pradesh. The case, State of Himachal Pradesh vs. Sanjay Kumar & Anr., involved serious allegations of kidnapping and rape of a minor girl, but was ultimately dismissed by the Court due to material contradictions in the prosecutrix’s testimony and lack of corroborative evidence.

The case dates back to March 30, 2012, when a 14-year-old girl went missing from Sri Naina Devi temple in Bilaspur district, where she had accompanied her family for a religious gathering. According to the prosecution, the accused Sanjay Kumar, who was known to the victim’s family, kidnapped her in his car and allegedly raped her at a house in Rampur. The second accused, Chaman Shukla, was charged with helping cover up the crime under Section 201 of IPC. While the Trial Court had convicted both accused, the High Court of Himachal Pradesh later acquitted them, leading to the State’s appeal in the Supreme Court.

The Supreme Court, in its judgment delivered by Justices Ahsanuddin Amanullah and Prashant Kumar Mishra, carefully examined the evidence and noted several critical inconsistencies. The Court observed: “There is material contradiction in the statement of the Prosecutrix as to the date of commission of rape… the High Court has rightly concluded that the commission of rape by accused/Sanjay Kumar is not proved.” This observation referred to the victim’s changing statements about when and where the alleged rape occurred.

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The prosecution’s case relied heavily on the victim’s testimony, with the State’s counsel arguing that “the prosecutrix is naturally the most important witness beside other circumstantial evidence and the High Court has erroneously discarded the version of the prosecutrix on its face value.” However, the defense successfully pointed out that the victim had given contradictory accounts about crucial details – initially stating the rape occurred on March 31 at Chaman Shukla’s house, but later testifying it happened on March 30 at another location.

The judgment highlighted several weaknesses in the prosecution’s case: lack of DNA evidence despite semen being found on the victim’s clothes, failure to examine key witnesses who could corroborate the victim’s movements, and the victim’s admission that she never reported the alleged rape to anyone during her three-day ordeal. The Court noted: “She admits of not disclosing the fact of commission of rape to anyone in the village Rampur or to the villagers or accused/Chaman Shukla who brought her to the Police Station.”

In its conclusion, the Supreme Court emphasized the principle that in appeals against acquittal, interference is warranted only if the trial court’s view was impossible or perverse. The bench stated: “the view taken by the High Court is one plausible view considering the evidence on record, interference against the judgment of acquittal rendered by the High Court is not called for.” This reaffirms the judiciary’s cautious approach in overturning acquittals, especially in cases where the evidence presents multiple reasonable interpretations.

The judgment serves as an important reminder about the standards of proof required in criminal cases, particularly those involving serious charges like rape. While acknowledging the gravity of the allegations, the Court demonstrated its commitment to ensuring convictions are based on consistent, reliable evidence rather than emotional considerations alone.

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Petitioner Name: State of Himachal Pradesh.
Respondent Name: Sanjay Kumar & Anr..
Judgment By: Justice Ahsanuddin Amanullah, Justice Prashant Kumar Mishra.
Place Of Incident: Bilaspur, Himachal Pradesh.
Judgment Date: 23-04-2025.
Result: dismissed.

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