In a significant judgment, the Supreme Court of India set aside the conviction of two men accused in a 1998 gang rape case from Dehradun, holding that the prosecution failed to establish guilt beyond reasonable doubt. The Court found serious inconsistencies in the testimony of the prosecutrix and noted an unexplained delay in filing the First Information Report (FIR).
A bench comprising Justice Pankaj Mithal and Justice Prasanna B. Varale delivered the judgment on March 13, 2026, allowing the criminal appeal filed by the accused.
Background of the Case
The case dates back to April 7, 1998, when a woman alleged that four men forcibly took her to a nearby plot in Sanjay Colony, Dehradun, and raped her one after another. According to the complaint, the accused also threatened her with harm if she disclosed the incident.
However, the complaint was filed nearly three months and twenty-four days after the alleged incident, when the victim submitted a written report to the Senior Superintendent of Police, Dehradun. Based on the complaint, an FIR was registered under sections related to rape, mischief, and criminal intimidation of the Indian Penal Code.
Following investigation, the police filed a charge sheet against the four accused, and the Additional Sessions Judge, Dehradun convicted them under Section 376(2)(g) (gang rape) and Section 506 (criminal intimidation) IPC. Each was sentenced to 10 years of rigorous imprisonment along with a fine of ₹5,000.
The Uttarakhand High Court later upheld the conviction in 2012, observing that the victim’s testimony was trustworthy and that the delay in lodging the FIR had been explained.
Two of the accused approached the Supreme Court challenging the High Court’s decision. During the pendency of the appeal, the other two accused passed away.
Counsel for the appellants argued that the case contained serious contradictions between the FIR and the statements made by the prosecutrix during the investigation and trial. The defence also highlighted the long delay in reporting the incident and suggested that a prior dispute between the parties could have led to false implication.
The State, on the other hand, argued that the testimony of the prosecutrix clearly established the offence and that the accused were known to her, making identification straightforward.
After reviewing the evidence, the Supreme Court found that the prosecution’s case suffered from significant weaknesses.
The Court noted that the FIR was lodged more than three months after the alleged incident, and during that time the prosecutrix had not disclosed the incident even to her family members.
The bench observed that such conduct appeared unusual in the circumstances.
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“The complaint was submitted after three months of the occurrence and the prosecutrix did not disclose the incident to anyone, not even her husband,” the Court noted while examining the evidence on record.
The Court also highlighted that the woman claimed to have disclosed the incident to a woman named Rahees Fatima, but that witness was never examined in court.
Further, the judges pointed out that the entire case rested largely on the sole testimony of the prosecutrix, without corroborating witnesses or supporting evidence.
“The conviction can rest on the solitary testimony of the prosecutrix, provided it inspires confidence of the Court. In the present case, the version of the prosecutrix utterly fails to inspire confidence,” the bench observed.
The Court also found that material inconsistencies existed between different statements made by the prosecutrix during the investigation and trial.
While evaluating the case, the Court referred to its earlier decision in Vijayan v. State of Kerala (2008), where a conviction based solely on delayed and uncorroborated testimony was considered unsafe.
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The bench noted that in cases where the prosecution depends entirely on the testimony of the victim, the evidence must be reliable and convincing.
In the present case, the Court found that the prosecution failed to present medical evidence or other supporting material that could establish the allegations beyond reasonable doubt.
After analysing the record and hearing both sides, the Supreme Court concluded that the prosecution had failed to prove the charges beyond reasonable doubt.
The Court therefore allowed the appeal and set aside the judgments of the trial court and the Uttarakhand High Court.
As a result, the conviction and sentence imposed on the appellants were quashed.
The bench directed that the accused be released immediately if not required in any other case.
Case Title: Rajendra & Ors. v. State of Uttarakhand
Case No.: Criminal Appeal No. 264 of 2015
Decision Date: 13 March 2026
