Ratansinh Dalsukhhai Nayak v. State of Gujarat — Child Witness Testimony, Forensic Corroboration

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

This was a prosecution under Section 302 IPC in which a child of tender age had witnessed the offence, and the conviction rested substantially on that child’s evidence.

On the question of competency, the Supreme Court held that no particular age is prescribed as the determinative factor for a witness’s competence under Section 118 of the Evidence Act: all persons are competent to testify unless the court finds them incapable of understanding the questions put and of giving rational answers to them.

The trial court had itself analysed and examined the child witness’s evidence and her capacity to understand, and the courts below were held justified in relying on her testimony, particularly since it was supported by forensic reports.

The conviction, affirmed by the High Court, was upheld.

Status: conviction upheld through final appeal.

Why this belongs in the Forensic Docket: A useful precedent for handling child-witness testimony: competency turns on demonstrated capacity to understand and answer rationally, not on age thresholds, and courts will lean more confidently on such testimony when it is buttressed by forensic reports rather than standing alone.

Case details

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.