Injury Marks Not Necessary for Rape Conviction": Supreme Court’s Landmark Verdict in 40-Year-Old Case
- byPranay Jain
- 11 Mar, 2025
In a historic ruling, the Supreme Court has finally delivered justice in a rape case that dates back to March 1984, bringing closure to a prolonged 40-year legal battle. The case involved a tuition teacher who sexually assaulted his student, with the trial court convicting him in 1986. However, the case languished in higher courts for decades, as the accused used legal loopholes to delay the verdict.
Decades-Long Legal Battle
After the trial court sentenced the teacher to prison within two years of the crime, it took another 25 years for the Allahabad High Court to uphold the ruling. The Supreme Court then took another 15 years to deliver its final verdict, ultimately rejecting the defence’s argument that the absence of injury marks on the victim’s private parts undermined the rape charges.
The accused also argued that the sexual encounter was consensual, but the Supreme Court found ample evidence to convict him. A bench comprising Justices Sandeep Mehta and Prasanna B Varale emphasized that injury marks are not always required for rape convictions.
Supreme Court’s Key Observations
Quoting Justice Varale, “It is not necessary that in each and every case in which rape is alleged there has to be an injury to the private parts of the victim. It depends on the facts and circumstances of a particular case. Absence of injuries on the private parts of the victim is not always fatal to the case of the prosecution."
The Supreme Court also reaffirmed that a rape survivor’s testimony holds equal weight to that of an injured witness. A conviction can be based on the sole testimony of the victim if it aligns with other evidence.
Dismissal of Character Assassination Claims
In a significant move, the court dismissed the accused’s attempt to discredit the victim by attacking the character of her mother. The defence had claimed that the victim’s mother was a “woman of easy virtue” and had falsely accused the teacher. However, the court firmly rejected this, stating that the alleged moral character of the victim’s mother had no bearing on the case.
The Incident and Its Aftermath
The assault occurred on March 19, 1984, when the young girl attended tuition at her teacher’s house. The teacher had sent two other girls away on errands before locking the victim in a room and assaulting her. Despite her efforts to raise an alarm, it was only when her grandmother arrived that she was rescued.
Following the incident, the victim’s family faced immense pressure and threats from the local community and the accused’s family, delaying the filing of the FIR.
A Landmark Verdict in India’s Legal History
While the trial court acted swiftly in 1986, delivering justice in two years, it took another 38 years for the matter to reach its final conclusion in the Supreme Court.
This ruling sets an important precedent in sexual assault cases, reinforcing that lack of injury marks does not negate a rape survivor’s testimony and that character assassination tactics will not be tolerated in legal proceedings.





