2026 Supreme(Online)(Chh) 10884

IN THE HIGH COURT OF CHHATTISGARH AT BILASPUR
Ramesh Sinha, CJ, Ravindra Kumar Agrawal, J
Santosh Kumar Sahu – Appellant
Versus
State of Chhattisgarh – Respondent
CRA No. 1607 of 2025

The testimony of a victim in sexual assault cases constitutes sufficient evidence for conviction if found trustworthy and consistent. Age determination for minor victims can be based on school records when properly proved, and such evidence provides a robust foundation for prosecution, especially when corroborated by objective medical and scientific data.

Headnote:(A) Bharatiya Nagarik Suraksha Sanhita, 2023 - Section 415(2) - Indian Penal Code, 1860 - Sections 376(2)(n), 376(3), 506 - Protection of Children from Sexual Offences Act, 2012 - Section 6 - Juvenile Justice (Care and Protection of Children) Act, 2015 - Section 94 - Sexual assault on minor - Proof of age - Determination of age in cases of child victims - Rule 12 of Juvenile Justice (Care and Protection of Children) Rules, 2007, provides a structured methodology for age determination - Documentary evidence such as school admission registers and marksheets are relevant and hold evidentiary value when proved by official custodians - The absence of specific primary documents does not render school records inadmissible if they are corroborated by other oral and documentary evidence. (Paras 30-38)

(B) Evidence - Testimony of victim - Sufficiency for conviction - Courts should not view testimony of victim of sexual assault with suspicion - When evidence is consistent, natural, and trustworthy, it can form the sole basis of conviction - Corroboration by medical evidence, such as findings of pregnancy and DNA profiling, further strengthens the prosecution's case and establishes the commission of the offence beyond reasonable doubt. (Paras 44-64)

Facts of the case:
The appellant was convicted by the trial court for aggravated sexual assault and criminal intimidation against a minor victim. The prosecution relied upon school records to establish the victim's age, medical reports confirming pregnancy, and a DNA report to prove paternity. The appellant challenged the conviction, arguing that the age determination lacked rigor, that there was a delay in lodging the first information report, and that the prosecutrix's testimony was inconsistent.

Findings of Court:
The court found the evidence of the victim, her mother, and the medical expert to be consistent and reliable. The age of the victim was clearly established as being below eighteen years at the time of the incident based on consistent school records and corroborated by oral evidence. The medical and scientific evidence provided an unimpeachable foundation for the charges, and the defence failed to rebut the state's case.

Issues: The main issues were the determination of the victim's age in accordance with statutory guidelines and whether the testimony of the victim, combined with medical evidence, was sufficient to sustain a conviction.

Ratio Decidendi: The legal standard for determining age in child victim cases, while borrowing from juvenile delinquency rules, allows for a holistic evaluation of evidence including school records in the absence of primary birth certificates. Furthermore, the testimony of a victim in sexual offence cases is of sterling quality if found cogent, rendering the requirement of further corroboration unnecessary when the narrative is reinforced by medical and scientific proof.

Result: Appeal dismissed.