Supreme Court Sets Aside Conviction of Four Men in 1998 Gang Rape Case Rajendra v State of Uttarakhand
The Supreme Court of India recently set aside the conviction of four men in a 1998 gang rape case, observing that the prosecution failed to prove the charges beyond reasonable doubt. The Court emphasized that although the testimony of a prosecutrix can be sufficient for conviction, it must be reliable, credible, and capable of inspiring confidence.
The ruling was delivered in Rajendra & Ors. v. State of Uttarakhand (2026 INSC 238) by a bench comprising Justice Pankaj Mithal and Justice Prasanna B. Varale. The Court allowed the appeal filed by the accused and quashed the judgments of the trial court and the High Court which had earlier convicted them.
Background of the Case
The case dates back to April 1998, when the prosecutrix alleged that she had been abducted and gang-raped by the accused persons. The FIR in the case, however, was lodged after a delay of about three months and twenty-four days.
The trial court convicted the accused under Section 376(2)(g) of the Indian Penal Code (IPC) for gang rape and Section 506 IPC for criminal intimidation. The High Court subsequently upheld the conviction and sentence imposed by the trial court.
Aggrieved by the decision, the accused approached the Supreme Court challenging the findings of the lower courts.
Supreme Court’s Observations on Evidence
The Supreme Court reiterated the well-settled principle that a conviction in a rape case can be based solely on the testimony of the prosecutrix if it is trustworthy and reliable. However, if the testimony suffers from inconsistencies or does not inspire confidence, courts must seek corroboration before recording a conviction.
After examining the evidence on record, the Bench found that the prosecution’s case suffered from several infirmities and lacked supporting material evidence.
The Court observed:
“In the face of lack of any other evidence, it is unsafe to convict the accused.”
The Bench further noted:
“The material on record does not clearly establish the guilt of the accused person and the prosecution has not proved its case beyond reasonable doubt.”
The Court also noted the absence of medical evidence supporting the allegation of rape, which further weakened the prosecution’s case.
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Delay in Lodging the FIR
Another important factor considered by the Court was the significant delay in lodging the FIR. While acknowledging that delay alone cannot be a ground to discard a rape complaint, the Court observed that in the present case the delay remained insufficiently explained.
Such delay, when coupled with inconsistencies in the testimony, created serious doubts regarding the prosecution’s version of events.
Disclosure of the Incident
The Court also expressed concern about the manner in which the alleged incident was disclosed.
The Bench observed that the prosecutrix did not disclose the incident to her husband or close family members for a considerable period. Instead, she reportedly disclosed it to a woman who was unknown to her and who was not examined as a witness during the trial.
The Court remarked:
“It would have been natural for the prosecutrix to disclose the incident to her family members after some time and not to somebody who is unknown to her.”
The Bench further observed:
“We find it hard to believe that such a grave incident was not disclosed by the complainant even to her husband at any point.”
These circumstances, according to the Court, weakened the credibility of the prosecution’s narrative.
Contradictions and Lack of Corroboration
The Supreme Court found several inconsistencies in the statements of the prosecutrix and noted that the prosecution had failed to produce corroborative evidence supporting the allegations.
While reiterating that courts must adopt a sensitive approach in cases involving sexual offences, the Bench stressed that the fundamental principle of criminal jurisprudence—proof beyond reasonable doubt—cannot be diluted.
The Court stated that when evidence fails to inspire confidence, it becomes unsafe to sustain a conviction.
Supreme Court’s Final Verdict
In light of these findings, the Supreme Court allowed the appeal and set aside the conviction and sentence imposed on the accused.
The Court concluded that the prosecution failed to establish the charges beyond reasonable doubt and that the benefit of doubt must go to the accused.
Accordingly, the appellants were acquitted of all charges and directed to be released if not required in any other case.
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