Latest JudgementIndian Evidence Act, 1872

Baddam Prashanth Reddy vs. State of Andhra Pradesh, 2025

The case reinforces the safeguard under Section 118 to prevent wrongful convictions based on untested child testimony.

Telangana High Court·18 December 2025
Baddam Prashanth Reddy vs. State of Andhra Pradesh, 2025
Indian Evidence Act, 1872
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Judgement Details

Court

Telangana High Court

Date of Decision

18 December 2025

Judges

Justice J. Sreenivas Rao

Citation

Acts / Provisions

Section 13(1)(ia), Hindu Marriage Act, 1955

Section 25, Hindu Marriage Act, 1955

Facts of the Case

  • The accused, Baddam Prashanth Reddy, was convicted by the Special Sessions Judge under Section 377 IPC for allegedly committing sexual assault on a minor male student.

  • The victim, a child, reported that the accused, his tuition teacher, forced himself on him and threatened him with poor grades if he disclosed the act.

  • The victim confided in a friend, who informed the mother, and the father filed a police complaint.

  • During the trial, the trial court convicted the accused relying primarily on the child’s testimony (minor PW.2) and the potency certificate (Ex.P3).

  • The victim and his father refused medical examination, leading to absence of corroborative medical evidence.

Issues

  1. Whether the trial court erred in convicting the accused solely based on the child’s testimony without conducting a competency assessment under Section 118 of the Evidence Act?

  2. Whether the child’s testimony was reliable and untutored?

  3. Whether the absence of medical corroboration affected the validity of the conviction?

Held

  • Conviction based solely on uncorroborated child testimony without competency assessment is legally unsustainable.

  • Mandatory compliance with Section 118 is necessary to ensure the child witness is competent.

Analysis

  • The case reinforces the safeguard under Section 118 to prevent wrongful convictions based on untested child testimony.

  • The judgment highlights the need for preliminary judicial inquiry into the child’s ability to testify, ensuring justice and fairness.

  • It serves as a binding precedent for cases where the entire conviction is based on a minor’s statement without corroboration.