Sole Testimony of the Prosecutrix, if Reliable, is Sufficient for Conviction: Chhattisgarh High Court Upholds Conviction in Sexual Assault Case
The Chhattisgarh High Court dismissed the appeal in CRA No. 1188 of 2022, upholding the conviction of Lalchand Rohra under sections 376(2)(f)(n), 376(a)(b) of the IPC and Section 5(L)(M)(N), 6 of the POCSO Act. The court reinforced the principle that the cogent and credible testimony of a minor victim is sufficient for conviction in cases of sexual assault, even in the absence of corroborative physical injuries.
Facts and Issues Arising in Judgment:
The appellant, Lalchand Rohra, was accused and convicted of sexually assaulting his minor daughter repeatedly. The trial was based largely on the victim’s testimony, which was found to be consistent and reliable despite the absence of physical evidence of assault. The key issue in the appeal was whether the testimony of the minor alone was sufficient to uphold the conviction given the absence of physical injuries.
Detailed Court Assessment:
Credibility of Minor’s Testimony:
The court noted that the testimony of the victim was consistent with her statements during the investigation and trial. Despite typical variations expected from a young child’s account, her detailed and unchallenged narrations of the incidents formed a reliable basis for conviction.
Legal Precedents and Principles:
The judgment cited multiple precedents from the Supreme Court affirming the sufficiency of a minor victim’s testimony as the sole basis for conviction in sexual assault cases. The court emphasized the severe impact of such crimes on minors and underscored the judiciary’s responsibility in safeguarding their rights under the POCSO Act and IPC.
Application of Law to Facts:
The court rejected the appellant’s claims of false implication, pointing out that the medical evidence did not negate the occurrence of sexual assault as the absence of physical injury does not conclusively rule out assault.
Decision: The High Court upheld the life imprisonment sentence and fines imposed by the trial court, dismissing the appeal for lack of merit and supporting the conviction based solely on the credible testimony of the minor victim.
Date of Decision: 09 April 2024
Lalchand Rohra vs State of Chhattisgarh
