Criminal Procedure Code vs State Of Odisha on 25 June, 2026

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    Orissa High Court

    Criminal Procedure Code vs State Of Odisha on 25 June, 2026

    Author: Sanjeeb K Panigrahi

    Bench: Sanjeeb K Panigrahi

                                                                    Signature Not Verified
                                                                    Digitally Signed
                                                                    Signed by: BHABAGRAHI JHANKAR
                                                                    Reason: Authentication
                                                                    Location: ORISSA HIGH COURT,
                                                                    CUTTACK
                                                                    Date: 08-Jul-2026 17:14:15
    
    
    
    
                  IN THE HIGH COURT OF ORISSA AT CUTTACK
    
                                 CRLA No. 489 of 2023
                                       and
                                 CRLA No.483 of 2023
           (In the matter of applications under Section 415(2) of Bharatiya
           Nagarik Suraksha Sanhita, 2023 corresponding to Section 374(2) of
           Criminal Procedure Code, 1973).
           Pramod Bariha                              ....                  Appellant (s)
           (In CRLA No.489 of 2023)
           Abhilash Bariha @ Bariha
           (In CRLA No.483 of 2023)
                                           -versus-
    
           State of Odisha                            ....            Respondent (s)
    
         Advocates appeared in the case throughHybrid Mode:
    
           For Appellant (s)           :               Mr. Dipti Ranjan Swain, Adv.
                                                              Mr. S.S. Ray (2), Adv.
    
           For Respondent (s)          :                     Ms. Gayatri Patra, ASC
                     CORAM:
                     DR. JUSTICE SANJEEB K PANIGRAHI
    
                         DATE OF HEARING:-08.04.2026
                        DATE OF JUDGMENT:-25.06.2026
         Dr. Sanjeeb K Panigrahi, J.
    

    1. Since both the CRLAs arise out of the same factual background and

    involve the same issue, those were heard together and are being

    SPONSORED

    disposed of by this common judgment.

    2. In both the above-mentioned Criminal Appeals, the Appellants seek a

    direction from this Court to set aside the judgment of conviction and

    sentence passed by the learned Special Judge, Bolangir, challenging

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    the POCSO conviction, the finding of minority, and the reliance

    placed on the prosecutrix’s testimony.

    I.    FACTUAL MATRIX OF THE CASE:
    
     3.   The brief facts of the case are as follows:
    
          (i)     On the night of 03.04.2016, when the parents of the victim were
    
    

    away from village Salebarat, accused Abhilash Bariha visited

    her house in the evening on the pretext of purchasing a hen and

    paid Rs. 200/- for it. Later that night between 9 and 10 PM, both

    accused Pramod Bariha and Abhilash Bariha returned on the

    same pretext, and upon the victim opening the door, Abhilash

    caught hold of her, gagged her mouth, pulled and dragged her,

    and both accused together lifted and carried her to Gidhghar

    Pahada, a hillock near the village.

    (ii) The victim was kept confined at GidhgharPahada from the night

    of 03.04.2016 until the morning of 05.04.2016, spanning two

    nights and one day. During this period, both accused allegedly

    tied her, denied her food throughout, and repeatedly committed

    rape on her. On the morning of 05.04.2016, the accused brought

    her down from the Pahada and abandoned her near her house,

    whereafter she disclosed the entire incident to gathered villagers

    and subsequently to her parents, police, and the Magistrate.

    (iii) The father of the victim, Dambarudhar Sahu (PW-1), lodged an

    FIR on 04.04.2016 at Sindhekela PS stating that his minor

    daughter had gone missing from the house and that gold

    ornaments worth about one and a half bhari were also missing.

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    He suspected kidnapping by someone who had seduced her.

    The police registered PS Case No. 71/2016 under Section 363

    IPC, and after investigation, submitted chargesheet on

    05.07.2016 under Sections 363, 366, 376(D) IPC and Section 6 of

    the POCSO Act. The Special Court framed charges on 08.03.2017

    under Sections 363, 366, 376(D), 376(2)(n) IPC and Sections 6 and

    10 of the POCSO Act.

    (iv) The prosecution examined 18 witnesses in total. PW-2 is the

    victim and sole eyewitness. PW-1 and PW-3 are her father and

    mother who deposed about receiving telephonic news of her

    disappearance and what the victim disclosed upon her return.

    PW-4 and PW-5 are co-villagers who heard the account from the

    victim herself when she was abandoned near her house. PW-7

    and PW-12 are medical officers who examined the two accused

    respectively, found them potent and fit for sexual

    consummation, but found no current signs of recent sexual

    intercourse, attributing the absence to regular bathing over the

    intervening two-day period. PW-13 is the medical officer who

    examined the victim on 05.04.2016 and found recent signs of

    sexual intercourse, rupture of hymen, fresh tear in hymenal

    opening, multiple abrasions on the right wrist and inner thighs,

    and clothes soiled with mud and whitish discharge; she assessed

    the victim’s age as between 14 and 18 years.

    (v) PW-16 and PW-17 are the current and former Headmasters of

    Govt. PUPS Salebarat respectively, who produced and proved

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    the school admission register (Ext-13) showing the victim’s date

    of birth as 17.12.1999, which would make her 16 years, 3 months

    and 17 days old on the date of occurrence. PW-18 is the

    investigating officer who proved the seizure of the admission

    register and other material documents. The defence examined

    no witnesses and took the plea of complete denial and false

    implication on account of prior enmity over a village pond

    construction dispute.

    II. SUBMISSIONS ON BEHALF OF THE APPELLANTS:

    4. The learned counsel for the Appellants respectfully and earnestly

    made the following submissions in support of his contentions:

    (i) The appellants challenged the applicability of the POCSO Act

    primarily by attacking the evidentiary value of the school

    admission register. They argued that PW-17, the Headmaster

    who produced the register, expressly admitted in cross-

    examination that he could not state the basis on which the date

    of birth entry of 17.12.1999 was made, since he was not working

    at the school at that time. Placing reliance on the Supreme

    Court’s decision in Birka Shiva v. State of Telangana1, the

    appellants contended that a school admission register whose

    entries cannot be traced to any primary source document cannot

    be treated as conclusive proof of the victim’s age.

    (ii) The appellants contended that the trial court committed a

    fundamental legal error by invoking Section 34 of the POCSO

    1
    (2024) SCC OnLine SC 3758

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    Act for determining the age of the victim, pointing out that the

    said provision governs age determination of the accused in

    conflict with law, not the victim. Applying it to the victim, they

    argued, was a wholly misconceived approach that rendered the

    entire POCSO conviction jurisdictionally infirm. They further

    relied on PW-13’s medical opinion placing the victim’s age

    between 14 and 18 years to argue that she could equally have

    been a major on the date of occurrence, taking her outside the

    definition of “child” under Section 2(1)(d) of the POCSO Act.

    (iii) On the question of voluntariness, the appellants relied on the

    contents of the FIR itself, arguing that PW-1’s own written

    report stated that the victim had “gone somewhere” and that

    gold ornaments were found missing from the house, which they

    submitted was consistent with the victim having left voluntarily,

    possibly in elopement. They further pointed to the medical

    officer PW-13’s finding that the victim was “habituated to sexual

    intercourse” as evidence that she was not a stranger to

    intercourse and had willingly accompanied the accused, thereby

    negating the foundational ingredient of force or enticement

    required under Section 363 IPC.

    (iv) On the identification and specific involvement of appellant

    Pramod Bariha, the appellants argued that the prosecutrix’s own

    deposition did not mention his name in the initial and critical

    portions of her account describing the abduction and the assault.

    His name surfaced only in the concluding portion of her

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    narrative, specifically at the point of being “lifted,” which the

    appellants submitted raised a strong doubt that his implication

    was an afterthought and possibly motivated by the pre-existing

    village enmity between the families.

    (v) On the general credibility of the prosecution case, the appellants

    argued that no independent eyewitness saw either the

    abduction or the confinement despite the occurrence taking

    place in a village setting and the Pahada being only

    approximately 2 km away. They highlighted that PW-4 and PW-

    5 were purely hearsay witnesses having heard the account from

    the victim herself after her return, and that Baidi Sahu, who

    allegedly witnessed the original hen purchase, was never

    examined by the prosecution, constituting a deliberate

    withholding of an available witness. The appellants also pointed

    to the complete absence of any village meeting after the incident,

    which they argued would normally follow such a grave event in

    a village community and whose absence indicated the story was

    fabricated at a later stage.

    III. SUBMISSIONS ON BEHALF OF THE RESPONDENT (STATE):

    5. The learned counsel for the State respectfully and earnestly made the

    following submissions in support of his contentions:

    (i) The State defended the school admission register as a public

    document maintained in regular course, produced from proper

    custody, and duly proved through multiple witnesses including

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    PW-16, PW-17, and PW-18. It submitted that under the Juvenile

    Justice Act framework made applicable through Section 34 of

    the POCSO Act, such a document carries a statutory rebuttable

    presumption of correctness as to the recorded date of birth. The

    State crucially pointed out that despite cross-examining PW-1,

    PW-2, and PW-18 at length, the defence never put a specific

    suggestion to any of them that the date of birth entry in the

    register was incorrect, fabricated, or entered on a wrong basis,

    which amounts in law to acceptance of that entry by the defence,

    leaving the presumption unrebutted.

    (ii) The State strongly defended the prosecutrix’s testimony as the

    foundational pillar of the prosecution case, relying on the settled

    position in State of H.P. v. Raghubir Singh2 and State v. Gurmit

    Singh3 that a conviction can be based solely on the testimony of

    the prosecutrix if it is consistent, credible, and withstands cross-

    examination. The State submitted that PW-2’s account remained

    consistent across her statement to police, her Section 164 Cr.P.C.

    statement before the Magistrate, and her deposition before the

    trial court, and that her veracity was not materially shaken in

    cross-examination. It also relied on State of Orissa v. Thakara

    Besra4 to emphasise that non-examination of certain witnesses is

    not a fatal infirmity when those witnesses did not witness the

    commission of the offence itself.

    2
    (1993) 2 SCC 622
    3
    (1996) 2 SCC 384
    4
    (2002) 9 SCC 86

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    (iii) On the absence of physical signs on the accused, the State relied

    on the categorical depositions of PW-7 and PW-12, both

    qualified medical officers, who explained that the accused were

    examined two days after the alleged incident and had bathed

    regularly in the intervening period. Both doctors stated clearly

    that such bathing is sufficient to eliminate biological traces and

    symptoms of recent intercourse, and that this was precisely the

    reason no such signs were found on examination. The State

    argued that this expert medical explanation was unchallenged

    by any contrary scientific opinion from the defence, and

    therefore no inference favourable to the accused could be drawn

    from the absence of these markers.

    (iv) On the charge of gang rape under Section 376(D) IPC, the State

    relied on Ashok v. State5 to submit that it is not necessary to

    prove a completed act of rape by each individual accused

    separately. It is sufficient to establish that the accused acted in

    concert with a common intention to commit the offence, and

    each member of the group becomes liable for the act as if done

    by him alone. The State submitted that the prosecutrix’s account

    of both accused participating jointly from the initial abduction

    through the entire period of confinement and assault established

    this common intention clearly and beyond reasonable doubt.

    (v) On the plea of false implication, the State submitted that no

    woman, particularly a minor girl, would voluntarily expose

    5
    (2003) 2 SCC 143.

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    herself to the shame, trauma, and hostile cross-examination

    inherent in a rape trial merely to settle a score over a village

    pond dispute. It further submitted that the medical evidence of

    PW-13, including fresh hymenal tear, multiple abrasions, and

    soiled clothing examined only hours after the victim’s return,

    constituted objective and independent corroboration that was

    wholly inconsistent with a narrative of voluntary elopement and

    consensual intercourse.

    IV. ANALYSIS OF THE JUDGMENT OF THE LOWER COURT:

    6. The Learned Trial Court made the following observations:

    (i) On age determination, the trial court adopted a doctrinally

    correct layered approach. It noted the oral evidence of PW-1

    placing the victim at about 16 years 3 months and the medical

    estimate of PW-13 as contextual background, but ultimately

    anchored its finding on the school admission register (Ext-13)

    recording the date of birth as 17.12.1999. Applying the JJ Act

    framework via Section 34 of the POCSO Act and following the

    Supreme Court’s direction in Jarnail Singh v. State of Haryana6,

    the court placed the burden of rebuttal on the defence. Since the

    defence failed to challenge the specific entry through any of the

    available prosecution witnesses during cross-examination, the

    court treated the entry as unrebutted. The defence’s reliance on

    Birka Shiva was effectively distinguished on facts, since that case

    involved an active challenge to the basis of entry, whereas here
    6
    (2013) 7 SCC 263

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    no such challenge was ever put to any witness, making the

    present case clearly distinguishable on that ground.

    (ii) On the prosecution’s argument that Section 34 was being

    applied to the victim rather than the accused, the trial court’s

    reasoning, while somewhat compressed, was substantively

    sound. The court used Section 34 as a procedural gateway to

    import the JJ Act‘s age-determination hierarchy, which places

    school records at the top, and applied that hierarchy to resolve

    the question of the victim’s age. The criticism that Section 34

    applies only to accused persons is a legitimate textual argument,

    but the court’s pragmatic borrowing of the procedure for the

    victim’s age determination in the absence of a specific statutory

    provision for the same under the POCSO Act reflects a

    purposive interpretation aimed at protecting the child victim,

    which higher courts have generally endorsed in the post-Jarnail

    Singh era.

    (iii) On the appreciation of the prosecutrix’s testimony and the

    hearsay evidence of PW-4 and PW-5, the trial court admitted the

    latter under Section 6 of the Indian Evidence Act as part of the

    same transaction, since the victim’s immediate disclosure upon

    being abandoned near her house constituted part of the res

    gestae of the entire criminal transaction. The court found PW-2’s

    testimony consistent, natural, and corroborated on material

    particulars by the medical evidence of PW-13.

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    (iv) The court applied the principle in Bimal Suresh v.

    ChaluverapinakeApal7 and State v. Gurmit Singh8 that

    conviction can rest on sole testimony of the prosecutrix when it

    inspires confidence, and found that her evidence not only

    survived cross-examination but was materially supported by

    independent medical and physical evidence. The court also

    correctly invoked Gurucharan v. State9 to hold that absence of

    vaginal canal injuries does not negate rape when the victim is a

    minor, since the lack of violent resistance by a minor does not

    imply consent and is fully explicable by the victim’s age and

    helplessness.

    (v) On sentencing and the statutory framework, the court’s

    application of Section 42 of the POCSO Act to avoid awarding

    double punishment for the same act under both IPC and POCSO

    is legally accurate and reflects correct understanding of the non-

    obstante clause contained therein. The court also correctly held

    that the 2019 amendment to Section 6 of the POCSO Act

    enhancing minimum punishment to 20 years could not be

    applied to an offence committed in April 2016, since penal

    amendments are presumed prospective unless made expressly

    or by necessary implication retrospective, which this

    amendment was not.

    7
    AIR 2003 SUPREME COURT 818
    8
    (1996) 2 SCC 384
    9
    AIR 1972 SC 2661

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    (vi) The award of 20 years RI under Section 376(D) IPC as the greater

    punishment, direction for concurrent running of sentences, set-

    off of pre-conviction detention under Section 428 Cr.P.C., victim

    compensation under Section 357 Cr.P.C., and DLSA

    compensation of Rs. 4 lakhs together reflect a comprehensive

    and victim-centric sentencing order. The one significant gap in

    the judgment is the absence of any independent discussion or

    analysis on the conviction under Section 376(2)(n) IPC, which

    requires proof of repeated rape by the same person on the same

    woman. Despite framing charge under this provision, the court

    convicted under it without separately evaluating the evidence

    specific to that ingredient.

    V. COURT’S REASONING AND ANALYSIS:

    7. Heard Learned Counsel for the parties and perused the documents

    placed before this Court.

    8. The factual matrix has been set out in the impugned judgment and

    need not be recapitulated in extenso. Suffice it to state that the

    appellants stand convicted by the learned Special Judge, Bolangir

    under Sections 363, 366, 376(D) and 376(2)(n) of the Indian Penal

    Code, 1860 and Sections 6 and 10 of the Protection of Children from

    Sexual Offences Act, 2012 (hereinafter “the POCSO Act“). They have

    been sentenced to undergo rigorous imprisonment for twenty years

    and to pay a fine of Rs. 10,000/- each under Section 376(D) IPC, with

    default stipulations. Sentences on remaining counts have been

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    directed to run concurrently. Being aggrieved, the appellants have

    preferred this Criminal Appeal.

    9. Having heard learned counsel for the appellants and the learned

    Additional Government Advocate for the State and having perused

    the entire trial court record, I find that the following issues arise for

    determination:

    a) Whether the prosecution has established that the victim was a

    “child” within the meaning of Section 2(1)(d) of the POCSO Act

    on the date of the occurrence?

    b) Whether the testimony of the prosecutrix (PW-2) is credible,

    consistent and sufficient to sustain conviction?

    c) Whether the ingredients of the offences under Sections 363, 366

    and 376(D) IPC are established beyond reasonable doubt?

    d) Whether the conviction under Section 376(2)(n) IPC is

    sustainable?

    e) Whether the sentence awarded by the trial court calls for any

    interference?

    10. The foundational question is whether the victim was below 18 years

    of age on 03.04.2016, the date of the occurrence. The POCSO Act

    defines “child” under Section 2(1)(d) as any person below the age of

    eighteen years. The prosecution relies on three strands of evidence: (a)

    the oral testimony of PW-1, the father, who stated that the victim was

    about 16 years and 3 months old; (b) the medical opinion of PW-13,

    who assessed the victim’s age as between 14 and 18 years; and (c) the

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    school admission register (Ext-13) maintained at Govt. PUPS,

    Salebarat recording the victim’s date of birth as 17.12.1999.

    11. The appellants have attacked the evidentiary value of Ext-13 primarily

    on the ground that PW-17, the former Headmaster who produced the

    register, admitted in cross-examination that he could not state the

    basis on which the date of birth entry was made, since he was not

    posted at the school at the relevant time. Reliance was placed on Birka

    Shiva v. State of Telangana (supra), to urge that a school register

    whose foundational basis is unknown cannot constitute reliable proof

    of age.

    12. I have considered this submission carefully. The law on age

    determination of a child victim under the POCSO Act has been

    authoritatively laid down by the Supreme Court in Jarnail Singh v.

    State of Haryana10wherein the Court approved the hierarchy

    prescribed under Rule 12 of the Juvenile Justice (Care and Protection

    of Children) Rules, 2007, placing the school register or matriculation

    certificate at the top of the evidentiary hierarchy. The Rule 12(3)

    specifically reads as follows:

    “In every case concerning a child or juvenile in conflict with
    law, the age determination inquiry shall be conducted by the
    Court or the Board or, as the case may be, the Committee by
    seeking evidence by obtaining-

    (a) (i) the matriculation or equivalent certificates, if
    available; and in the absence whereof;

    (ii) the date of birth certificate from the school (other than a
    play school) first attended; and in the absence whereof;

    10
    (2013) 7 SCC 263

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    (iii) the birth certificate given by a corporation or a
    municipal authority or a panchayat.”

    13. Likewise, in Shah Nawaz v. State of U.P.11, the Supreme Court held

    that a date of birth entry in a school register, being a document

    maintained in the regular course of business of the institution and

    produced from proper custody, carries a presumption of correctness

    under, unless the contrary is affirmatively established by the party

    challenging it.

    14. The critical distinction between the present case and Birka Shiva

    (supra) lies in the manner the challenge was mounted. In that case, the

    defence actively challenged the basis of the entry through specific

    cross-examination and adduced material to demonstrate that the entry

    was unreliable. In the present case, the defence adopted a

    fundamentally different strategy. Despite prolonged cross-

    examination of PW-1, PW-2, PW-16 and PW-18, at no point was a

    specific suggestion put to any witness that the date of birth entry of

    17.12.1999 in Ext-13 was incorrect, fabricated, or entered on an

    erroneous basis. This omission is of decisive significance.

    15. In fact, Laxmibai (Dead) Thr. L.Rs v. Bhagwantbuva (Dead) Thr.

    L.Rs12the Supreme Court reiterated the settled rule that where a party

    seeks to dispute the correctness of a witness’s statement, the witness

    must be specifically confronted with that part of the testimony in

    cross-examination. In the absence of such confrontation, the credibility

    of the witness cannot later be impeached on that point, and the

    11
    (2011) 13 SCC 751
    12
    (2013) 4 SCC 97

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    unchallenged part of the evidence may be relied upon by the Court.

    The Court held as follows:

    “Furthermore, there cannot be any dispute with respect to
    the settled legal proposition, that if a party wishes to raise
    any doubt as regards the correctness of the statement of a
    witness, the said witness must be given an opportunity to
    explain his statement by drawing his attention to that part
    of it, which has been objected to by the other party, as being
    untrue. Without this, it is not possible to impeach his
    credibility. Such a law has been advanced in view of the
    statutory provisions enshrined in Section 138 of the
    Evidence Act, 1872, which enable the opposite party to
    cross-examine a witness as regards information tendered in
    evidence by him during his initial examination in chief, and
    the scope of this provision stands enlarged by Section 146 of
    the Evidence Act, which permits a witness to be questioned,
    inter-alia, in order to test his veracity.”

    16. In the present case, the failure of the defence to challenge the specific

    entry, when ample opportunity existed, leaves the statutory

    presumption attaching to Ext-13 wholly unrebutted.

    17. As regards the appellants’ objection that the trial court erroneously

    invoked Section 34 of the POCSO Act, which textually governs the age

    determination of “a person accused of any offence,” I note that while

    the textual criticism has some force, the trial court’s approach was

    substantively sound. The court used Section 34 as a procedural

    conduit to import the well-established JJ Act hierarchy for age

    determination. In the absence of a dedicated statutory provision under

    the POCSO Act for determining the age of the child victim, courts

    have consistently and pragmatically applied the same hierarchy. The

    Supreme Court’s approval of this hierarchy in Jarnail Singh (supra)

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    was not confined to the accused alone but was stated as a general

    principle for age determination in cases involving children. I see no

    jurisdictional infirmity in the trial court’s approach.

    18. The medical opinion of PW-13 placing the victim’s age “between 14

    and 18 years” does not detract from this finding. It is settled law that

    medical opinion on age is at best an approximation and must yield to

    documentary evidence when available. The range of 14 to 18 years is

    entirely consistent with the date of birth of 17.12.1999, which would

    make the victim 16 years, 3 months and 17 days old on 03.04.2016.

    Accordingly, I hold that the prosecution has established beyond

    reasonable doubt that the victim was a child within the meaning of

    Section 2(1)(d) of the POCSO Act on the date of the occurrence. Issue

    (i) is answered in the affirmative.

    19. Now, the Court must move to the issue of the credibility of the

    prosecutrix. The appellants have attacked the credibility of PW-2 on

    several grounds: the absence of independent eyewitnesses, the alleged

    delayed naming of appellant Pramod Bariha in her account, the

    finding of PW-13 that she was “habituated to sexual intercourse,” and

    the non-examination of Baidi Sahu, the alleged witness to the hen

    purchase.

    20. The law governing the evidentiary value of a prosecutrix’s testimony

    is well settled. In Gurmit Singh (supra) the Supreme Court held that

    the testimony of a victim of sexual assault stands on the same footing

    as the testimony of an injured witness. The Court held as follows:

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    “The testimony of the victim in such cases is vital and
    unless there are compelling reasons which necessitate
    looking for corroboration of her statement, the courts should
    find no difficulty to act on the testimony of a victim of
    sexual assault alone to convict an accused where her
    testimony inspires confidence and is found to be reliable.
    Seeking corroboration of her statement before relying upon
    the same, as a rule, in such cases amounts to adding insult
    to injury. Why should the evidence of a girl of a woman who
    complains of rape or sexual molestation, be viewed with
    doubt, disbelief or suspicion? The Court while appreciating
    the evidence of a prosecutrix may look for some assurance of
    her statement to satisfy its judicial conscience, since she is a
    witness who is interested in the outcome of the charge
    levelled by her, but there is no requirement of law to insist
    upon corroboration of her statement to base conviction of an
    accused. The evidence of a victim of sexual assault stands
    almost at par with the evidence of an injured witness and to
    an extent is even more reliable. Just as a witness who has
    sustained some injury in the occurrence, which is not found
    to be self-inflicted, is considered to be a good witness in the
    sense that he is least likely to shield the real culprit, the
    evidence of a victim of a sexual offence is entitled to great
    weight, absence of corroboration notwithstanding.
    Corroborative evidence is not an imperative component of
    judicial credence in every case of rape. Corroboration as a
    condition for judicial reliance on the testimony of the
    prosecutrix is not a requirement of law but a guidance of
    prudence under given circumstances. It must not be over-
    looked that a woman or a girl subjected to sexual assault is
    not an accomplice to the crime but is a victim of another
    persons’s lust and it is improper and undesirable to test her
    evidence with a certain amount of suspicion, treating her as
    if she were an accomplice. Inferences have to be drawn from
    a given set of facts and circumstances with realistic
    diversity and not dead uniformity lest that type of rigidity
    in the shape of rule of law is introduced through a new form

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    of testimonial tyranny making justice a casualty. Courts
    cannot cling to a fossil formula and insist upon
    corroboration even if, taken as a whole, the case spoken of by
    the victim of sex crime strikes the judicial mind as
    probable.”

    21. I have examined the testimony of PW-2 with care. Her account is

    detailed and specific: she describes the evening visit of Abhilash

    Bariha on the pretext of purchasing a hen for Rs. 200/-, the return of

    both accused between 9 and 10 PM, the manner in which Abhilash

    caught hold of her and gagged her mouth while Pramod assisted in

    lifting and carrying her to Gidhghar Pahada, the tying of her hands,

    the denial of food over two nights and one day, and the repeated

    commission of rape by both accused. This account remained

    consistent across her statement under Section 161 Cr.P.C., her Section

    164 statement before the learned Magistrate, and her deposition before

    the trial court. During extensive cross-examination, the defence could

    not elicit any material contradiction or omission that would shake the

    foundations of her testimony.

    22. The submission that appellant Pramod Bariha’s name surfaced

    belatedly in her narrative is, upon careful reading of the deposition,

    not borne out. PW-2 specifically stated that both accused came

    together to her house between 9 and 10 PM, and that while Abhilash

    caught hold of her, both of them together lifted and carried her to the

    Pahada. The natural sequence of narration, describing the acts of each

    participant as they occurred, does not amount to belated implication.

    23. It must be made clear that the testimony of a victim of sexual assault

    cannot be treated as if it were the testimony of an accomplice. The

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    prosecutrix is not a participant in the crime; she is the person against

    whom the crime is alleged to have been committed. To approach her

    evidence with an initial presumption of suspicion only because the

    allegation relates to a sexual offence would be legally unsound. It is,

    in fact, an anomaly that such doubt is often suggested in cases of

    sexual offences, though no similar presumption is ordinarily applied

    to victims of other crimes. A victim of assault, robbery, kidnapping or

    attempt to murder is not treated as inherently suspect merely because

    he or she is the complainant. There is no reason why a different and

    more burdensome standard should be applied to a prosecutrix. The

    defence is entitled to test her evidence through cross-examination, but

    it cannot ask the Court to begin from a position of distrust merely

    because she is the victim of the offence alleged.

    24. Moreover, the finding of PW-13 that the victim was “habituated to

    sexual intercourse” is equally unavailing to the appellants. It is firmly

    settled that evidence of prior sexual experience is irrelevant to the

    question whether the prosecutrix was raped on the date of the

    occurrence. Section 53A of the Indian Evidence Act and the proviso to

    Section 146 of the same Act, inserted by the Criminal Law

    (Amendment) Act, 2013, expressly prohibit drawing any inference

    from a victim’s prior sexual experience as to her consent or credibility

    in a rape trial. In any event, the victim being a child of 16 years, the

    question of consent is entirely immaterial by virtue of Section 3 read

    with Section 5 of the POCSO Act.

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    25. This Court finds the said submission wholly untenable. It is difficult

    to appreciate how such an argument could have been advanced at all,

    in the face of the clear statutory position and the settled principles

    governing appreciation of evidence in sexual offences. What legal

    consequence can possibly follow from the observation that the

    prosecutrix was “habituated to sexual intercourse”? Does it disprove

    the occurrence alleged? Does it establish consent? Does it render the

    testimony of a minor victim less credible in law? The answer to each

    of these questions is plainly in the negative.

    26. The argument seeks to shift the focus from the conduct of the

    appellants to the supposed past conduct of the victim, which is

    impermissible. A criminal trial cannot be converted into an inquiry

    into the character of the prosecutrix. The only relevant issue is

    whether the offence alleged was committed by the appellants on the

    date and in the manner stated by PW-2. In the present case, the

    prosecutrix was a minor, and therefore the plea becomes even more

    unsustainable. The appellants cannot be permitted to draw any

    advantage from such a legally irrelevant and plainly misconceived

    submission, and the same is rejected.

    27. The submission, in substance, is a poor attempt to make a legally

    irrelevant circumstance do the work of evidence. It answers none of

    the material facts in the prosecution case. It does not disprove the

    taking away of the prosecutrix, it does not explain the confinement, it

    does not meet the allegation of sexual assault, and it certainly does not

    make the testimony of a sixteen-year-old child unreliable. It is, at best,

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    a desperate effort to grasp at a medical observation and use it to cast

    aspersions on the victim. Such an argument is precisely the kind of

    victim-blaming which the law does not permit. The appellants are on

    trial for their alleged conduct. The prosecutrix is not on trial for her

    character. This Court cannot countenance an attempt to divert

    attention from the accusation by placing a minor victim under moral

    scrutiny. The submission is therefore deprecated and rejected.

    28. Regarding the non-examination of Baidi Sahu, the Supreme Court in

    Thakara Besra(supra) held that non-examination of a witness who is

    not an eyewitness to the commission of the offence itself does not

    constitute a fatal infirmity in the prosecution case. Baidi Sahu

    allegedly witnessed only the purchase of the hen in the evening,

    which is not even a disputed fact. His examination would not have

    added materially to the prosecution case. Similarly, PW-4 and PW-5,

    to whom the victim narrated the events immediately upon being

    abandoned near her house, were correctly admitted by the trial court

    as res gestae witnesses under Section 6 of the Indian Evidence Act.

    Their testimony constitutes the immediate and spontaneous

    declarations of the victim forming part of the same transaction and

    lends natural corroboration to her account.

    29. I am satisfied that the testimony of PW-2 is consistentand trustworthy.

    It inspires judicial confidence and stands corroborated on material

    particulars by independent medical and physical evidence. Issue (ii) is

    answered in the affirmative.

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    30. Now, the Court must move to the third issue. Section 363 IPC

    punishes kidnapping from lawful guardianship. Under Section 361,

    whoever takes or entices any minor under sixteen years of age if a

    male, or under eighteen years of age if a female, out of the keeping of

    the lawful guardian of such minor without the consent of such

    guardian, is said to kidnap such minor from lawful guardianship. The

    victim being a female minor of 16 years at the date of the occurrence,

    the statutory threshold is satisfied. The evidence of PW-2 establishes

    that she was taken from her house, where she was in the constructive

    keeping of her parents (PW-1 and PW-3), against her will and without

    the knowledge or consent of her parents.

    31. The contention that the victim went voluntarily, based on the FIR’s

    reference to her having “gone somewhere” and gold ornaments being

    missing, is without substance. The FIR was lodged by PW-1 on

    04.04.2016 when the victim had not yet returned and the full facts

    were not known to him. It is settled law that the FIR is not an

    encyclopaedia of the prosecution case and that subsequent revelations

    do not impeach it. In Amish Devgan v. Union of India13, the Supreme

    Court held that FIR is not a detailed chronicle of all intricate and

    minute details of an offence. The relevant excerpts are produced

    below:

    “Acronym FIR, or the First Information Report, is neither
    defined in the Criminal Code nor is used therein, albeit it
    refers to the information relating to the commission of a
    cognisable offence. This information, if given orally to an

    13
    AIRONLINE 2020 SC 930

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    officer in-charge of the police station, is mandated to be
    reduced in writing. Information to be recorded in writing
    need not be necessarily by an eye-witness, and hence, cannot
    be rejected merely because it is hearsay. Section 154 does not
    mandate nor is this requirement manifest from other
    provisions of the Criminal Code. Further, FIR is not meant
    to be a detailed document containing chronicle of all
    intricate and minute details. In Dharma Rama Bhagare v.
    State of Maharashtra,118
    it was held that an FIR is not
    even considered to be a substantive piece of evidence and can
    be only used to corroborate or contradict the informant’s
    evidence in the court.”

    32. The contention regarding voluntary departure is further belied by the

    unshaken testimony of PW-2 that Abhilash caught hold of her, gagged

    her mouth, and both accused physically lifted and carried her to the

    Pahada. The consent of a minor is, in any event, wholly immaterial in

    law for the purpose of Section 361 IPC.

    33. Section 366 IPC requires proof that the kidnapping or abduction was

    with the intent that the victim may be compelled or induced to have

    illicit intercourse. The sequence of events, namely the abduction of the

    victim at night, her confinement at a secluded hillock for two nights

    and one day, and the commission of repeated rape during that period,

    leaves no room for doubt that the taking was with the intent

    contemplated by Section 366. The ingredients of Section 366 IPC are

    fully established.

    34. Turning to Section 376(D) IPC, which deals with gang rape, I note that

    the offence is made out where a woman is raped by one or more

    persons constituting a group or acting in furtherance of a common

    intention. The Supreme Court in Ashok (supra) held that it is not

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    necessary to prove a completed act of penetrative sexual assault by

    each individual accused separately. Where two or more persons act

    together with a common intention to commit rape, each is liable for

    the act done by any of them in furtherance of that common intention.

    35. In the present case, PW-2’s testimony establishes that both appellants

    came together, abducted her jointly, confined her at the Pahada, and

    both committed rape on her during the period of confinement. The

    joint participation from inception to completion of the criminal design

    establishes the common intention beyond reasonable doubt. The

    absence of physical signs of recent intercourse on the accused, as

    noted by PW-7 and PW-12, has been satisfactorily explained by both

    medical officers, who categorically stated that regular bathing over the

    intervening two-day period before examination was sufficient to

    eliminate biological traces. This expert explanation was not challenged

    by any contrary medical evidence from the defence side, and no

    adverse inference can be drawn against the prosecution on this

    account. The ingredients of Section 376(D) IPC are fully established.

    36. The defence plea of false implication on account of village enmity over

    a pond construction dispute deserves to be rejected. A woman,

    particularly a minor, would not ordinarily subject herself to the

    ordeal, humiliation and hostile cross-examination inherent in a rape

    trial merely to settle scores with her adversary. The absence of any

    village meeting after the incident is of no consequence; there is no rule

    of evidence or common experience that mandates such a meeting as a

    precondition for the credibility of a complaint. The medical evidence

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    of PW-13, documenting fresh hymenal tear, multiple abrasions on the

    right wrist and inner thighs, and clothes soiled with mud and whitish

    discharge, examined only hours after the victim’s return, constitutes

    powerful objective corroboration wholly inconsistent with a theory of

    fabrication. Issue (iii) is answered in the affirmative.

    37. Now this Court must turn to the fourth issue, which pertains to the

    Conviction under Section 376(2)(n) of IPC. Section 376(2)(n) IPC, as it

    stood at the relevant time, prescribes enhanced punishment where a

    person commits rape repeatedly on the same woman. The essential

    ingredient of this provision is that the same accused must be shown to

    have committed rape on the same victim on more than one occasion.

    The trial court, while framing charge and recording conviction under

    this provision, did not undertake any independent analysis of

    whether the evidence established repeated acts of rape by each

    individual accused on the victim.

    38. I have examined the evidence on this point. PW-2 stated that “both

    accused repeatedly committed rape on her” during the period of

    confinement spanning two nights and one day. This general

    statement, while establishing the overall course of conduct, does not

    particularise how many times each individual accused committed the

    act, at what intervals, and in what sequence. The expression

    “repeatedly” in the victim’s account, read in the context of a joint

    confinement involving two accused, makes it inherently difficult to

    segregate individual acts attributable to each accused for the purpose

    of Section 376(2)(n).

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    39. However, this shortfall is of no practical consequence to the final

    result. The conviction and sentence under Section 376(D) IPC, which

    carries the same minimum punishment of 20 years rigorous

    imprisonment (post-Criminal Law Amendment Act, 2013), already

    stands sustained. The trial court itself awarded the substantive

    sentence under Section 376(D) and directed all other sentences to run

    concurrently. In the interest of precision, the conviction under Section

    376(2)(n) IPC is set aside, without this having any bearing on the

    substantive sentence or any other conviction.

    40. Lastly, this Court must turn to the final issue, which pertains to the

    requirement of the interference into the sentence of the trial court. The

    trial court awarded rigorous imprisonment of twenty years with a fine

    of Rs. 10,000/- under Section 376(D) IPC, which is the minimum

    prescribed sentence. The trial court applied Section 42 of the POCSO

    Act to avoid double punishment for the same act under both IPC and

    POCSO. It also correctly held that the 2019 amendment to Section 6 of

    the POCSO Act enhancing the minimum punishment to twenty years

    could not be applied retrospectively to an offence committed in April

    2016. The direction for concurrent running of sentences, set-off of pre-

    conviction detention under Section 428 Cr.P.C., victim compensation

    under Section 357 Cr.P.C., and DLSA compensation of Rs. 4,00,000/-

    reflect a lawful and comprehensive sentencing order. I find no ground

    for interference with the sentence.

    VI. CONCLUSION:

    41. For the foregoing reasons, this Court holds as follows:

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    a) The conviction of both appellants under Sections 363, 366 and

    376(D) of the Indian Penal Code, 1860 and under Sections 6 and 10

    of the POCSO Act, 2012 is hereby confirmed.

    b) The conviction under Section 376(2)(n) of the Indian Penal Code is

    set aside.

    c) The sentence of rigorous imprisonment for twenty years with fine

    of Rs. 10,000/- under Section 376(D) IPC, with all other sentences

    running concurrently, is confirmed.

    d) The direction for set-off of pre-conviction detention under Section

    428 Cr.P.C., victim compensation under Section 357 Cr.P.C., and

    DLSA compensation of Rs. 4,00,000/- shall remain undisturbed.

    e) The default stipulations as imposed by the trial court shall

    continue to operate.

    42. It is made clear that the setting aside of the conviction under Section

    376(2)(n) IPC does not result in any alteration of the sentence imposed

    upon the appellants. The substantive sentence of rigorous

    imprisonment for twenty years with fine of Rs.10,000/- under Section

    376(D) IPC, being the operative sentence, stands confirmed. Since the

    remaining sentences were directed to run concurrently, the

    modification indicated above does not reduce, vary, or otherwise

    affect the total sentence to be undergone by the appellants.

    43. The Criminal Appeals are, accordingly, partly allowed to the extent of

    setting aside the conviction under Section 376(2)(n) IPC, and are

    dismissed in all other respects. The impugned judgment and order of

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    conviction and sentence passed by the learned Special Judge, Bolangir

    is confirmed subject to the modification indicated above.

    44. The appellants, who are stated to be in custody, shall continue to

    serve the sentence as imposed.

    45. Interim order, if any, passed earlier stands vacated.

    (Dr. Sanjeeb K Panigrahi)
    Judge
    Orissa High Court, Cuttack,
    Dated the 25th June, 2026/

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