1. Court’s decision
The Supreme Court has overturned the conviction of two young men who had been found guilty under assault provisions of the Penal Code and under sections of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act. The Court held that the prosecution evidence suffered from material inconsistencies, internal contradictions and omissions so significant that sustaining the conviction would result in grave miscarriage of justice. It found that the High Court misread testimony, ignored hostile-witness evidence favourable to the defence, and returned a perverse finding of caste-based motive unsupported by the record. The Supreme Court therefore set aside the conviction and sentence, discharged the appellants from their bail bonds, and allowed the appeal in full.
2. Facts
The case arose from a written complaint by a school-going girl who alleged that the appellants approached her home at night, asked whether anyone was present, and that one of them pulled her dupatta and scratched her neck. She stated that her younger brother intervened, at which both appellants beat him and abused him. An FIR was registered the next day. Medical examination recorded only simple injuries. The trial court convicted the first appellant under Section 323 IPC and the second appellant under Sections 354, 323 IPC and Section 3(1)(xi) of the atrocities law. The High Court affirmed these convictions. On further appeal, the Supreme Court examined the entire evidence to ascertain whether the convictions could stand.
3. Issues
The Supreme Court considered the following issues:
- Whether the victim’s testimony, when compared with the FIR and medical evidence, sustained the charges of assault and outraging modesty.
- Whether corroborative evidence existed to support the alleged involvement of both appellants.
- Whether contradictions in the statements of the victim and her brother, especially regarding injuries and sequence of events, undermined the prosecution’s case.
- Whether caste-based intent, essential for conviction under the atrocities law, was established beyond reasonable doubt.
- Whether the High Court erred in ignoring the deposition of a hostile witness whose testimony cast serious doubt on the prosecution narrative.
- Whether the defence’s alternative account of a scuffle at a crowded Ganesh festival could reasonably explain the injuries.
4. Petitioners’ arguments
The appellants argued that the prosecution case was fabricated following a scuffle at a crowded Ganesh puja pandal. They contended that the victim’s brother, PW-2, had been involved in the scuffle and subsequently concocted a false version, attributing indecent conduct to the appellants. They highlighted inconsistencies between the FIR and testimony, contradictions on how the appellants arrived, discrepancies about the location and nature of injuries, and absence of independent witnesses despite PW-2 claiming that many locals saw the incident. They emphasised that the medical officer found only simple injuries consistent with a fall. They also argued that no witness testified to caste-based motive and that the High Court’s presumption of such motive was perverse.
5. Respondent’s arguments
The State supported the conviction, relying on the testimony of the victim and PW-2, asserting that their statements were sufficient to sustain the charges. It argued that minor inconsistencies were natural in cases of this nature and that the trial court and High Court had concurrently accepted the prosecution version. It maintained that the injuries matched the victim’s account of being scratched and the brother’s account of assault. However, the State had no explanation for the failure to produce any independent witnesses despite claims of numerous onlookers, nor could it address why the medical evidence did not record key injuries asserted in testimony.
6. Analysis of the law
The Supreme Court reiterated that credibility of witnesses must be weighed against internal consistency, corroboration, natural conduct, and medical evidence. Contradictions touching the core of the prosecution story cannot be brushed aside as minor. The Court emphasised that when medical findings contradict material aspects of testimony, the benefit of doubt must follow. On the atrocities charge, the Court underscored the requirement of clear proof of caste-based intent; mere knowledge of the victim’s caste is insufficient. The Court further reaffirmed the well-settled principle that testimony of hostile witnesses is not to be discarded wholesale, but carefully examined to ascertain whether portions support the defence.
7. Precedent analysis
The Court relied on State of U.P. v. Ramesh Prasad Misra (1996) 10 SCC 360, quoted in the judgment, reiterating that hostile-witness evidence must be scrutinised and may be accepted to the extent it supports either side. The trial and appellate courts had wrongly ignored PW-4’s testimony, which suggested an accidental scuffle at the pandal and contradicted the prosecution version. The Court also invoked general criminal law doctrines that contradiction between medical and ocular evidence shakes prosecution credibility. Established jurisprudence on atrocities cases requires explicit proof of caste-based intention — a requirement unmet here. The conviction under Section 3(1)(xi) was therefore legally unsustainable.
8. Court’s reasoning
Several contradictions proved fatal to the prosecution:
• The FIR claimed A-2 accompanied A-1; the victim testified he arrived later after a phone call.
• The victim said her brother arrived after hearing her scream; PW-2 stated he came after someone informed him of a fight.
• The victim said PW-2 bled from the head and chest; PW-2 claimed injury to nose and mouth; the doctor found no such injuries.
• Neither the nail mark on the victim’s back nor evidence of injury from wood blows was reflected in the medical report.
• PW-2 claimed “many people” witnessed the incident; none were examined.
• PW-4’s testimony supported the defence that the scuffle occurred at a crowded pandal, and that the narrative of teasing at home was improbably substituted.
• No witness testified that the alleged assault occurred because of the victim’s caste.
Given these deficiencies, the Court held the prosecution story unreliable and the High Court’s findings perverse.
9. Conclusion
The Supreme Court concluded that the prosecution failed to prove its case beyond reasonable doubt. The evidence did not establish that the appellants assaulted the victim or her brother in the manner alleged. The Court found no reliable basis to convict the second appellant for outraging modesty or under the atrocities law, and no basis to convict either appellant under assault provisions. The conviction and concurrent sentences were set aside. The appellants were acquitted and discharged from their bail bonds. The appeal was allowed in its entirety.
10. Implications
This ruling reinforces rigorous evidentiary standards in criminal cases, especially when enhanced penalties under the atrocities law are invoked. The Court’s insistence on proof of caste-based motive ensures that misapplication of the Act is avoided while preserving its purpose. The decision also clarifies that contradictions between testimony and medical evidence can undermine entire prosecutions, and that failure to examine independent witnesses in cases allegedly witnessed by many persons is a serious prosecutorial lapse. The judgment strengthens protections against wrongful convictions and reaffirms the judiciary’s duty to scrutinise evidence in cases involving young victims and socially sensitive allegations.
CASE LAW REFERENCES
1. State of U.P. v. Ramesh Prasad Misra, (1996) 10 SCC 360
Holding: Evidence of a hostile witness is not to be rejected entirely; admissible portions supporting either prosecution or defence must be considered.
Applied: The Supreme Court relied on this to fault the High Court for ignoring PW-4’s testimony.
2. Standard SC/ST Act jurisprudence
Holding: Conviction requires proof that the offence was committed because the victim belonged to a Scheduled Caste.
Applied: No such proof existed; High Court’s finding was termed perverse.
3. Medical-ocular contradiction doctrine
Authorities hold that material contradiction between eyewitness testimony and medical evidence casts serious doubt on prosecution.
Applied: PW-5’s injury findings undermined core prosecution claims.
SEO-FRIENDLY FAQs
1. Why did the Supreme Court acquit the accused in this case?
Because the prosecution evidence was riddled with contradictions, unsupported by medical findings, and lacked independent corroboration. The hostile witness also undermined the core narrative.
2. What did the Court say about the caste-based allegations?
The Court held that no evidence showed the alleged assault occurred because the victim belonged to a Scheduled Caste, making the atrocities conviction unsustainable.
3. How did medical evidence affect the case?
Medical examination recorded only simple injuries inconsistent with the prosecution story. The doctor confirmed such injuries could occur from a fall, supporting the defence version.