2026 Supreme(Online)(Chh) 11307

IN THE HIGH COURT OF CHHATTISGARH AT BILASPUR
Ramesh Sinha, CJ, Ravindra Kumar Agrawal, J
Madvi Hidma – Appellant
Versus
State Of Chhattisgarh – Respondent
CRA No. 128 of 2024

In sexual assault cases involving minors, the testimony of the victim, if found cogent and trustworthy, is sufficient for conviction without medical corroboration. Sentencing must adhere to the principle of proportionality, balancing the gravity of the violation with the possibility of reformation.

Headnote:(A) Indian Penal Code, 1860 - Sections 450, 363, 366, 324, 376(AB) - Protection of Children from Sexual Offences Act, 2012 - Section 6 - Aggravated penetrative sexual assault - Determining age of victim - Documentary evidence like school records holds primacy - Absence of internal medical injuries or forensic traces does not invalidate testimony of a child victim where such testimony is cogent and inspires confidence - Testimony of a sole victim, if found trustworthy, does not require corroboration - Procedural irregularities in identification parade do not vitiate conviction if independent evidence supports identification. (Paras 11, 13, 18, 19, 20, 26)

(B) Sentencing - Principles of proportionality - Sentencing must balance gravity of offence with reformative justice - Life imprisonment for remainder of natural life reduced to twenty years rigorous imprisonment in consideration of factual matrix and established precedent. (Paras 31, 32)

Facts of the case:
The victim, a child, was abducted from a residential facility and subjected to sexual assault. The defense challenged the conviction on grounds of contradictory testimony, absence of physical medical evidence, and alleged tutoring, while disputing the age of the victim and the veracity of identification procedures.

Findings of Court:
The court found the victim's testimony to be consistent and credible. The age was conclusively proved via school records. It held that sexual assault on a minor is a severe violation of bodily integrity, and while medical corroboration is helpful, it is not mandatory for conviction when the victim's statement is reliable.

Issues: Whether the conviction for aggravated sexual assault against a minor is sustainable based on the victim's testimony alone absent forensic medical corroboration, and whether the sentence of life imprisonment for the duration of natural life is appropriate under the established sentencing guidelines.

Ratio Decidendi: The testimony of a child victim of sexual assault constitutes substantive evidence and can form the basis of a conviction without external corroboration. Punishment for such offenses must be proportionate to the gravity of the assault, adhering to both the protection of the victim's rights and the requirement for a just, non-excessive sentence tailored to the circumstances of the offender and the offense.

Result: Appeal partly allowed; conviction upheld but sentence modified to 20 years of rigorous imprisonment.