Judgment Intelligence
Conviction Set Aside- Court
- Supreme Court of India
- Date of Decision
- 25 September 2026
- Bench
- Justices Ujjal Bhuyan and Atul S. Chandurkar
- Relevant Acts & Sections
- IPC Sections 366, 375 and 376 (rape provisions as applicable before the 2013 amendment); IPC Sections 359, 361, 362; Evidence Act Section 114A
The Supreme Court set aside the Sessions Judge, Ludhiana’s judgment and order dated 1 June 2012 and the Punjab and Haryana High Court’s judgment and order dated 12 September 2013. It cleared the appellant of the Section 376 charge and allowed the appeal. (Paras 30–31)
Key holdings
- A conviction may rest on the prosecutrix’s sole testimony, provided it inspires the court’s confidence. (Para 28)
- For these intertwined charges, the Court rejected reliance on the same testimony to sustain Section 376 after its rejection for Section 366. (Paras 28–29)
- Immorality alone cannot justify conviction without credible evidence; judicial value judgments cannot replace proof. (Para 29)
- The Court accepted that accompanying a man or spending a night with him need not involve consent to intercourse, while distinguishing this case’s evidence. (Para 27)
Brief Facts
The prosecution alleged non-consensual intercourse during June 2009. The Sessions Judge acquitted Bedi under Section 366 IPC but convicted him under Section 376, imposing ten years’ rigorous imprisonment and a fine of ₹5,000. The High Court affirmed that conviction. (Paras 3–7)
The trial court accepted the prosecutrix’s age as 19 after finding that the prosecution had not proved she was under 18. The Supreme Court endorsed the Section 366 findings and noted that they remained unchallenged. (Paras 20.1–21)
Court's Findings
The Supreme Court identified conflicting accounts of the return journey: PW-1 described travel by car in examination-in-chief but by train in cross-examination. Assessing her evidence as a whole, it found her account unreliable. (Paras 15.6, 24–26)
It also considered her conduct during travel when assessing her account of involuntary confinement. These were the Court’s assessments of this witness and these circumstances; its recognition of the distinction between accompanying someone and consenting to intercourse remained express. (Paras 24–27)
Medical testimony recorded no external or genital injuries. The Supreme Court held that spermatozoa in the vaginal swab did not establish rape in the surrounding circumstances. Neither observation is presented here as an independent test of consent. (Paras 18–18.1, 25)
Given the charges’ factual interconnection, the Court faulted the contrasting treatment of the same testimony under Sections 366 and 376. It rejected reliance on conjecture and the presiding judge’s value judgments to sustain conviction. (Paras 12, 28–29)
