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Puran Chand v. State of Himachal Pradesh — Medical Evidence Infirmity Claim Rejected

Part of the Forensic Docket on Legal Desire Forensics — a conviction confirmed through final appeal, kept here as a method-of-crime record.

The facts

The accused was convicted of the rape of a minor girl by the courts below.

On appeal, he raised three defences: delay in lodging the FIR, false implication due to enmity, and an alleged infirmity in the medical evidence.

The Supreme Court held that the delay in lodging the FIR had been fully explained and did not detract from the victim’s credibility.

Applying the amended Section 114-A of the Evidence Act, the Court held that the offence of rape would be taken as proved even on evidence of an attempt at rape, without requiring proof of actual completion of the act.

The prosecutrix’s testimony was found to have withstood cross-examination, and the conviction was upheld.

Status: conviction upheld through final appeal.

Why this belongs in the Forensic Docket: Illustrates how, under the amended Section 114-A, a rape conviction can rest on the survivor’s credible testimony alone — surviving both an FIR-delay challenge and a claimed medical infirmity — underscoring that a medical examiner’s findings are one strand of evidence among several, not a precondition for conviction.

Case details

Citation[2014] 5 S.C.R. 530
Case numberCriminal Appeal No. 1708/2010
CourtIndian Supreme Court
Decided2014-04-23
ModuleMO Archive

Read the full judgment (PDF), sourced from the Indian Supreme Court Judgments open dataset (AWS Open Data Registry, CC-BY-4.0).

Explore more in the Forensic Docket or browse the full Forensics hub.

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