Case Summary
Citation: 2025 INSC 1395
Court: Supreme Court of India
Bench: Justice Dipankar Datta & Justice Augustine George Masih
Date: 08 December 2025
📝 Background of the Case
Two appellants (A-1: Dadu @ Ankush; A-2: Ankit) were convicted by the Special Judge under the SC/ST (Prevention of Atrocities) Act and IPC for assault and outraging modesty of a Class XI girl.
The Madhya Pradesh High Court upheld the conviction.
The appellants approached the Supreme Court through Special Leave Petition.
⚖️ Key Allegations by the Prosecutrix
- She was home alone at night when A-1 and A-2 came.
- A-2 allegedly pulled her dupatta and scratched her neck.
- When her brother (PW-2) arrived, both accused allegedly beat him.
- Allegation that A-2 knew she was a Scheduled Caste girl and acted with caste-based intention.
👩⚖️ Supreme Court’s Analysis
The Supreme Court carefully analysed the written complaint, oral testimony, medical evidence, and contradictions.
1. Major Contradictions in Testimony
- FIR said A-2 accompanied A-1; in court she said A-1 called A-2 later.
- Victim did not say in court that the accused assaulted her because she was SC—contrary to High Court’s conclusion.
- PW-2 claimed he heard about a fight from someone but did not say he heard her screams.
2. Medical Evidence Did Not Match Prosecution Story
- Injuries on both the victim and PW-2 were simple and consistent with falling or being dragged, as admitted by Medical Officer (PW-5).
- No injury on nose/mouth of PW-2 despite his claim of bleeding.
- No nail marks on victim’s back though both PW-1 & PW-2 claimed so.
3. Missing Independent Witnesses
- PW-2 said “many people from locality saw the incident.”
- No independent or post-occurrence witness was examined.
- Court found this highly suspicious.
4. Hostile Witness Supporting Defence (PW-4)
- PW-4 suggested the entire issue arose from an overcrowded Ganesh Puja pandal where the accused may have stepped on PW-2’s feet, leading to a scuffle.
- Court held that even hostile testimony cannot be discarded entirely; the High Court wrongly ignored this.
5. SC/ST Act Charges Not Supported
- No evidence that the accused targeted the victim because of her caste.
- High Court’s finding was called “perverse”.
🔚 Final Judgment
The Supreme Court set aside the conviction of both appellants.
Reasons for Acquittal:
- Prosecution version found contradictory, unreliable, and improbable.
- Injuries did not support the prosecution narrative.
- Hostile witness’s testimony supported defence version of a scuffle.
- No evidence of caste-based intent under SC/ST Act.
- No convincing proof of outraging modesty or assault.
Outcome:
- Conviction and sentence quashed.
- Appellants acquitted and discharged from bail bonds.
📌 Key Takeaways for Lawyers & Students
- Hostile testimony is not to be thrown out; parts supporting defence/prosecution can still be relied upon.
- Inconsistencies between FIR, statements, and medical evidence can be fatal to prosecution.
- Caste-based offences require solid proof of intent, not just that the victim belongs to SC/ST community.
- Non-examination of independent witnesses when available weakens the prosecution case significantly.
