Key legal aspects of Lok Mal v. State of Uttar Pradesh, highlighting factual background, legal issues, and judgment.
SUPREME COURT UPHOLDS RAPE CONVICTION BASED ON SURVIVOR’S TESTIMONY
| ASPECTS | DETAILS |
| Case Title | Lok Mal @ Loku vs. State of Uttar Pradesh |
| Introduction | The case concerns a criminal appeal against a judgment by the Allahabad High Court affirming the conviction of the appellant under Sections 376 and 323 IPC. The trial court sentenced the appellant to 5 years of rigorous imprisonment for rape and 6 months for causing hurt. The Supreme Court upheld the conviction, emphasizing the credibility of the prosecutrix’s testimony and dismissing the appellant’s plea of false implication. |
| Factual Background | The prosecutrix, a tuition teacher, was sexually assaulted by the accused at his residence on March 19, 1984. She was gagged and overpowered, but the arrival of the accused’s nieces interrupted the crime. Due to threats from the accused’s family, the FIR was delayed but was eventually lodged. |
| Legal Issues |
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| Applicable Law |
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| Analysis | The Court held that medical corroboration is not mandatory if the prosecutrix’s testimony is trustworthy. The delay in filing the FIR was justified due to threats. The Court rejected the defense’s attempt to discredit the prosecutrix based on her mother’s alleged character. |
| Conclusion | The Supreme Court upheld the High Court’s judgment, stating that the prosecutrix’s testimony was reliable and supported by circumstances. The appeal was dismissed. The Court directed authorities to consider the appellant’s case for remission as per state policy. |
| Current Scenario | The judgment reaffirms the principle that a prosecutrix’s sole testimony, if credible, is sufficient for conviction. It strengthens the legal position that minor discrepancies and medical reports not showing injury do not invalidate a rape survivor’s testimony. |
CASE SUMMARY—In this case, the Supreme Court of India upheld the conviction of Lok Mal @ Loku for rape and causing hurt under Sections 376 and 323 IPC. The prosecutrix, a tuition teacher, was assaulted in the accused’s home, but the timely arrival of children disrupted the act. The Court rejected the accused’s defense of false implication and emphasized that medical corroboration is unnecessary when the survivor’s testimony is credible. The delay in FIR filing was justified due to threats. Referring to Gurmit Singh (1996) and Bharwada Bhoginbhai (1983), the Court reaffirmed that a rape survivor’s sole testimony is sufficient for conviction.
A rape survivor’s testimony, if credible, holds the same weight as an injured witness’s statement.
SOURCE- SUPREME COURT OF INDIA
