In a quiet but telling courtroom moment, the Supreme Court on Monday set aside the conviction of a Gujarat-based doctor accused of rape, bringing an end to a case that began way back in 2001. The bench, after carefully re-reading witness testimonies and medical reports, concluded that the prosecution had failed to prove its case beyond reasonable doubt. The judgment came as a reminder that serious allegations, however grave, must still stand on firm evidence.
Background
The case revolved around allegations made by a woman who claimed that her doctor sexually assaulted her during a medical examination at his clinic in Himmatnagar. An FIR was lodged soon after the incident, and the doctor was eventually charged under rape provisions of the Indian Penal Code.
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The trial court convicted him in 2003, sentencing him to six years in prison. Years later, the Gujarat High Court not only upheld the conviction but enhanced the sentence to ten years, agreeing with the State’s plea that the punishment awarded was below the statutory minimum. The doctor then approached the Supreme Court, challenging both the conviction and the sentence enhancement.
Court’s Observations
At the heart of the Supreme Court’s analysis was the testimony of the prosecutrix and her husband. Both, during trial, failed to support the prosecution story and were declared hostile. The bench noted that while a hostile witness’s statement cannot be thrown out entirely, courts must be cautious in placing reliance on it.
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“The court should be slow to act on the testimony of such a witness,” the bench observed, reiterating settled law that credibility becomes shaky when statements change over time.
The judges also examined the medical and forensic evidence. Doctors who examined both the complainant and the accused did not find injuries or signs clearly supporting recent sexual assault. Even the recovery of clothes and forensic reports, relied upon heavily by the High Court, came under scrutiny after panch witnesses admitted their signatures were taken on prepared documents without knowing the contents.
The bench was particularly critical of the assumption that the victim and her husband were “won over” by the accused. It noted that such a presumption cannot replace proof. As the court put it, allegations in an FIR, by themselves, cannot lead to conviction unless supported by solid evidence during trial.
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Decision
After considering the overall evidence, the Supreme Court held that both the trial court and the High Court had erred in convicting the appellant. The conviction and enhanced sentence were quashed, the appeals were allowed, and since the accused was already on bail, his bail bonds were discharged, finally closing the case after more than two decades.
Case Title: Jayantibhai Chaturbhai Patel v. State of Gujarat
Case No.: Criminal Appeal Nos. 890–891 of 2017
Case Type: Criminal Appeal (Rape conviction challenge and sentence enhancement)
Decision Date: December 16, 2025
