Criminal conviction cannot be sustained where prosecution evidence is inconsistent, uncorroborated, and fails to establish guilt beyond reasonable doubt

The Supreme Court of India has set aside the conviction of two accused persons after finding that the prosecution evidence suffered from serious inconsistencies, lack of independent corroboration, and material contradictions that rendered the case unreliable. The Court held that where witness testimonies do not inspire confidence and medical evidence does not support the prosecution version, a criminal conviction cannot be sustained.

Allowing the appeal, the Court overturned the judgment of the Madhya Pradesh High Court and acquitted the appellants of offences under the Indian Penal Code and the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989, holding that the findings of guilt were perverse and unsupported by the evidence on record.

Case Background

The case arose from an incident alleged to have occurred on 4 October 2015 in Sawargaon, Amba Ward, Pandhurna, involving the victim, a minor girl studying in Class XI, and her younger brother. The prosecution case was that when the victim was alone at home, the two appellants came to her house, allegedly teased her, and assaulted her brother when he intervened.

Based on a written complaint lodged by the victim, an FIR was registered and the appellants were tried before a Special Court under the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989.

What The Lower Authorities Held

The Special Court convicted the first appellant under Section 323 of the Indian Penal Code and sentenced him to three months’ rigorous imprisonment with fine. The second appellant was convicted under Sections 354 and 323 of the IPC as well as Section 3(1)(xi) of the SC/ST Act, and sentenced to one year’s rigorous imprisonment for the principal offences, with concurrent sentences.

The appellants challenged their conviction before the High Court of Madhya Pradesh under Section 374(2) of the Code of Criminal Procedure. The High Court dismissed the appeal, affirming the findings of the trial court.

The Court’s Reasoning

The Supreme Court examined the evidence led by the prosecution to determine whether the conviction of the appellants could be sustained. The Court undertook a careful scrutiny of the testimonies of the victim, her brother, medical evidence, and other witnesses.

Role attributed to the appellants

The Court noted that the victim did not attribute any physical act to the first appellant in her testimony. His role was limited to enquiring whether anyone else was present in the house. No act constituting an offence against the victim was proved against him.

As regards the second appellant, the prosecution alleged that he pulled the victim’s dupatta and scratched her. However, the Court found inconsistencies between the victim’s written complaint and her deposition in court regarding whether the second appellant had accompanied the first appellant or was called later.

Contradictions in witness testimonies

The victim’s brother, examined as PW-2, claimed that many people from the locality had witnessed the incident. However, no independent witness from the locality was examined by the prosecution. The Court found this omission significant, particularly when public presence was asserted.

The Court further noted inconsistencies between the victim’s version and PW-2’s testimony regarding how PW-2 came to the house and the nature of injuries suffered by him.

Medical evidence

The medical officer (PW-5) found only simple injuries on the victim and her brother, which could have been caused by a fall or dragging on the ground. The medical evidence did not support the prosecution’s version of assault with a wooden object or injuries on the nose and mouth as claimed by PW-2.

The Court also observed that certain injuries alleged by the prosecution witnesses did not find mention in the medical reports, further undermining the credibility of the prosecution case.

Statutory Interpretation

The Supreme Court examined the application of Sections 323 and 354 of the Indian Penal Code and Section 3(1)(xi) of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989, in the context of the evidence on record.

The Court reiterated that offences under the SC/ST Act require proof that the alleged act was committed on account of the victim’s caste. In the absence of any testimony establishing caste-based intent, conviction under the Act cannot be sustained.

Constitutional / Policy Context

While deciding the appeal, the Supreme Court situated its analysis within the fundamental principles governing criminal jurisprudence in India. The Court reiterated that the presumption of innocence is a cornerstone of criminal law and that an accused is entitled to benefit of doubt where the prosecution fails to establish guilt beyond reasonable doubt.

The Court emphasised that criminal courts must guard against conviction based on conjectures, moral suspicion, or emotionally charged narratives unsupported by reliable evidence. The requirement of proof beyond reasonable doubt is a foundational principle of criminal jurisprudence and must be strictly applied where the prosecution evidence suffers from inconsistencies or lacks corroboration.

The Court further underscored that enhanced penal statutes, such as the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989, must be applied with care and strictly in accordance with statutory requirements, so that the object of the law is achieved without compromising fairness to the accused.

Assessment of Evidence and Standard of Proof

The Supreme Court reaffirmed that the prosecution bears the burden of proving every ingredient of the alleged offences beyond reasonable doubt. Where the evidence led by the prosecution is inconsistent, contradictory, or unsupported by medical or independent evidence, courts must exercise caution before recording a conviction.

In the present case, the Court found that the testimonies of the prosecution witnesses did not form a coherent and consistent narrative. Material contradictions existed not only between the written complaint and oral testimony of the victim but also between the testimonies of the victim and her brother.

The Court reiterated that while minor discrepancies may be ignored, contradictions that go to the root of the prosecution case cannot be brushed aside, particularly when they relate to the presence of accused persons, the sequence of events, and the nature of injuries.

Non-Examination of Independent Witnesses

A significant factor that weighed with the Supreme Court was the prosecution’s failure to examine independent witnesses, despite claims that several people from the locality had witnessed the incident.

The Court observed that where the prosecution asserts the presence of independent witnesses and yet fails to examine any of them without explanation, such omission casts serious doubt on the veracity of the prosecution version.

The Court clarified that while conviction can be based on the testimony of a sole witness, such testimony must inspire confidence and be free from material contradictions. In the present case, the absence of independent corroboration further weakened an already fragile prosecution case.

Medical Evidence and Its Corroborative Role

The Supreme Court analysed the medical evidence in detail and reiterated that medical evidence serves as an important corroborative tool in criminal trials. Where medical findings contradict the ocular version, courts must carefully evaluate whether the prosecution story is reliable.

In this case, the medical officer’s testimony did not support the allegations of assault as narrated by the prosecution witnesses. Injuries claimed to have been caused by a wooden object or targeted blows were absent from the medical reports.

The Court held that such discrepancies could not be treated as minor inconsistencies, as they directly impacted the credibility of the alleged occurrence and the manner of assault.

Application of the SC/ST Act

The Supreme Court devoted particular attention to the conviction under Section 3(1)(xi) of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989.

The Court reiterated that for an offence under the SC/ST Act to be made out, it must be established that the accused committed the alleged act on the ground that the victim belonged to a Scheduled Caste or Scheduled Tribe. Mere proof of the victim’s caste status is insufficient.

In the absence of any evidence showing caste-based intent or motivation, the Court held that conviction under the SC/ST Act was wholly unsustainable.

Why This Judgment Matters

This judgment reinforces the principle that criminal courts must remain anchored to evidentiary discipline, particularly in cases involving serious allegations and enhanced penal consequences.

It clarifies that while courts must be sensitive to allegations of sexual assault and caste-based offences, such sensitivity cannot replace the requirement of reliable and cogent evidence.

The decision also serves as a reminder that misuse or overextension of special statutes dilutes their purpose and risks miscarriage of justice.

Final Outcome

The Supreme Court allowed the criminal appeal and set aside the judgment of the High Court of Madhya Pradesh affirming the conviction of the appellants.

The appellants were acquitted of all charges under the Indian Penal Code and the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989. The Court directed that they be released forthwith, if not required in any other case.

Case Details

• Case Title: Dadu @ Ankush & Anr. v. State of Madhya Pradesh & Anr.
• Citation: 2025 INSC 1395
• Court & Bench: Supreme Court of India; DIPANKAR DATTA J. and AUGUSTINE GEORGE MASIH J.
• Date of Judgment: 8 December 2025