Deepak Kumar Sahu versus State of Chhattisgarh, 2025
This ruling reinforces the principle that sexual assault convictions do not require corroborative medical evidence if the victim’s testimony is reliable.
Judgement Details
Court
Supreme Court of India
Date of Decision
6 August 2025
Judges
Justice Sudhanshu Dhulia ⦁ Justice NV Anjaria
Citation
Acts / Provisions
Section 13(1)(ia), Hindu Marriage Act, 1955
Section 25, Hindu Marriage Act, 1955
Facts of the Case
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The appellant was convicted for sexually assaulting a 15-year-old girl under the POCSO Act and the IPC.
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The conviction was challenged on the ground of lack of medical evidence showing physical intercourse and absence of external injury marks.
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The prosecution relied heavily on the victim’s testimony, which was consistent and credible throughout the trial.
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The Chhattisgarh High Court upheld the conviction, which was later challenged before the Supreme Court.
Issues
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Whether the testimony of the victim alone is sufficient to sustain a conviction in the absence of corroborative medical evidence?
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The legal impact of absence of external injury marks or detailed medical evidence in cases of sexual assault?
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The scope of evidentiary standards in rape and sexual assault cases, especially under the POCSO Act and IPC?
Held
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The conviction for sexual assault under Section 4 of POCSO and Section 376(2) IPC was upheld.
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The Credible testimony of the victim alone can sustain conviction even without corroborative medical evidence.
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The absence of injury or detailed medical findings is not fatal to the prosecution case.
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Legal standards prioritize the victim’s testimony when found consistent and credible.
Analysis
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This ruling reinforces the principle that sexual assault convictions do not require corroborative medical evidence if the victim’s testimony is reliable.
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The Court strengthens victim-centric judicial approaches, recognizing the difficulties of physical evidence in sexual crimes.
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Reliance on past precedents clarifies legal thresholds for proving rape beyond medical injury marks.
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The decision balances evidentiary rigour with practical realities of sexual assault cases, ensuring justice for victims.
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It also highlights the importance of child witness testimonies in corroborating victim statements.