Madhya Pradesh High Court Upholds Acquittal in POCSO Case Citing Prior Enmity and Lack of Evidence

Madhya Pradesh High Court Upholds Acquittal in POCSO Case Citing Prior Enmity and Lack of Evidence

Acquittal Stands: High Court Dismisses Victim and State Appeals

The High Court of Madhya Pradesh at Indore has upheld the acquittal of Jwala Singh in a case of alleged sexual assault of a minor, dismissing appeals filed by both the victim and the State. In a detailed judgment delivered on 20th August 2026, Justice Jai Kumar Pillai affirmed the trial court’s finding that the prosecution story was riddled with contradictions and failed to inspire confidence.

The Incident and the Investigation: A Timeline of Doubts

The case dated back to 5th March 2021, when the 12‑year‑old complainant claimed that while sweeping outside her house, her neighbour Jwala Singh caught her hand and tried to drag her towards a drain to commit a wrongful act. She alleged she freed herself, hit him with a broom, and ran to inform her brother. The police registered an FIR and filed a charge‑sheet under the Protection of Children from Sexual Offences Act and the Indian Penal Code.

However, the trial court found multiple inconsistencies and acquitted Singh on 20th February 2023. Aggrieved, both the victim and the State challenged the acquittal before the High Court.

A Narrative Unraveled: Prior Enmity and Fatal Admissions

The High Court delved into the evidence and noted a crucial admission from the complainant herself. During cross‑examination, she stated that her father had a verbal altercation with the accused’s father the day before the incident, and that her father filed the police report out of “sheer anger.” This prior enmity was corroborated by her father’s testimony, who admitted to a dispute over employment with Ashok Parmar.

The court observed that while prior enmity does not automatically discredit a witness, the complainant’s explicit acknowledgment that the FIR was motivated by anger cast a heavy shadow of doubt on the prosecution’s version.

Legal Precedents on Sole Testimony and Injuries

The appellant relied on the precedent in Vijay @ Chini vs. State of MP (2010) to argue that absence of injuries is immaterial. They also cited Karu Lal vs. State of MP (2020) to contend that prior enmity alone does not make witnesses unreliable. The High Court accepted these as settled law but held that each case must be judged on its own facts. Here, the glaring unnatural elements and lack of corroboration made the testimony unworthy of reliance.

The Court’s Reasoning: An Unnatural and Uncorroborated Story

Justice Pillai identified several fatal flaws in the prosecution case:

• No injury on the victim: Despite the accused being a strong 23‑year‑old and the victim a mere 12‑year‑old, the medical report showed zero injuries. The court found it unnatural that a forceful dragging would leave no defensive marks.

• No outcry: The victim admitted she did not shout or scream when allegedly being dragged. The court found this “completely unnatural” in a terrifying situation.

• Public location with no independent witnesses: The incident allegedly occurred at 5 PM in a densely populated residential area, near a hand pump frequented by women and opposite a school playground. Yet no independent eyewitness was examined.

• Geographical inconsistency: The alleged drain to which the victim was dragged was not shown in the spot map (Exhibit P‑2), casting doubt on the core narrative.

The court concluded that the defence had “entirely succeeded in refuting any initial presumption” and that the prosecution failed to prove its case beyond reasonable doubt.

Key Observations from the Judgment

> “The deliberate act of dragging a victim towards a public space when an isolated house was readily available appears contradictory and unnatural.”

> “Given the stark physical disparity, if the accused forcefully dragged her to commit a crime, she would have naturally sustained some defensive or friction injuries.”

> “The trial court rightly extended the benefit of the doubt to the accused. There is absolutely no manifest error, illegality, or perversity in the appreciation of evidence.”

Final Order: Benefit of the Doubt Upheld

The High Court dismissed both the victim’s appeal (CRA No. 9660/2023) and the State’s appeal (CRA No. 7483/2023), holding that the trial court’s view was “not only entirely reasonable but the only plausible conclusion” on the record. The accused, Jwala Singh, remains free of all charges, and the judgment of acquittal stands affirmed.

The ruling reinforces the principle that appellate courts will not lightly interfere with acquittals where the trial court’s factual assessments are well‑reasoned and based on the evidence. It also highlights the importance of independent corroboration and natural conduct in sexual assault cases, even when the victim is a minor.