The landmark judgement of State of Himachal Pradesh vs Sanjay Kumar 2025 drew significant attention due to the scrutiny by the Supreme Court of the reliability of the prosecutrix’s testimony in rape cases especially when inconsistencies exist. It also highlighted the importance of corroborative evidence like DNA testing and the role of Section 164 CrPC statements in determining the credibility of a victim’s account in sexual offence trials. Discover more in-depth analyses of important Supreme Court decisions by exploring Recent Judgements of Supreme Court.

State of Himachal Pradesh vs Sanjay Kumar 2025 Introduction

The landmark judgement State of Himachal Pradesh vs Sanjay Kumar 2025 revolved around serious allegations of kidnapping and rape of a minor girl by the accused Sanjay Kumar with the alleged involvement of Chaman Shukla in obstructing the investigation. After the Sessions Court convicted the accused, the Himachal Pradesh High Court acquitted them, prompting an appeal by the State before the Supreme Court.

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The case at hand centres around the alleged kidnapping and rape of a minor girl by the accused Sanjay Kumar and the subsequent alleged involvement of Chaman Shukla in misleading the investigation. The incident led to the registration of an FIR at Police Station Barmana, District Bilaspur (H.P.). After the conviction by the Sessions Court, the High Court of Himachal Pradesh acquitted both accused which led to the present appeals challenging that acquittal. The following are the facts of State of Himachal Pradesh vs Sanjay Kumar -

Challenge to the High Court Judgment

These appeals challenge the judgment of acquittal dated 28th December, 2015 passed by the High Court of Himachal Pradesh at Shimla. The High Court set aside the conviction and sentence of accused Sanjay Kumar under Section 363, Section 366, Section 376 and Section 201 r/w Section 34 of the Indian Penal Code, 1860 and of accused Chaman Shukla under Section 201 r/w Section 34 IPC. These convictions were initially imposed by the Sessions Judge, Bilaspur (H.P.).

Incident Leading to the FIR

On 30th March, 2012, Parkash Chand (PW-5), the father of the prosecutrix, was delivering a religious discourse ('Katha') at Sri Naina Devi temple, Sohra Buins. His wife, Shanta Sharma, daughter Tanu Sharma (PW-2) and the prosecutrix (PW-13) aged about 14 years, were present. During the event, PW-2 instructed the prosecutrix to put her two-year-old son to sleep in one of the temple rooms. When the prosecutrix did not return for a long time, PW-2 found the child sleeping alone and the prosecutrix missing. Despite searching, the family could not find her and suspected that Sanjay Kumar had kidnapped her. Narender Shail (PW-1) then filed a complaint at Police Station Barmana which led to the registration of the FIR.

Recovery of the Prosecutrix and Arrest of the Accused

On 1st April, 2012, Chaman Shukla took the prosecutrix to Police Station Rampur, District Shimla, claimed that he found her walking alone at Narkanda on 30th March, 2012 and had brought her home. A police team from Police Station Barmana and the prosecutrix’s relatives reached Rampur, and the prosecutrix was formally handed over after recording an entry in the Rojnamcha. Authorities arrested Sanjay Kumar on 4th April, 2012, and both he and the prosecutrix underwent medical examination.

Investigation Findings

During the investigation, police found that Sanjay Kumar had abducted the prosecutrix in his Alto car (registration No. HP-24-8684) on 30th March, 2012. That night, he stayed with her at the house of Jawala Devi (PW-6) in Thaila Chakti, Tehsil Rampur, District Shimla, where he allegedly committed rape. The following day, he took her to Chaman Shukla’s house. Chaman Shukla allegedly threatened the prosecutrix to falsely claim that she had travelled to Rampur voluntarily and attempted to mislead the investigation.

PW-6 handed over a shirt belonging to the prosecutrix to the police. The investigating officer also obtained the prosecutrix’s birth certificate which confirmed her date of birth as 9th December, 1997, a fact supported by the family register. On 7th April, 2012, police seized the car and a mobile phone with a Vodafone SIM card. On 11th April, 2012, the prosecutrix’s statement was recorded before the Judicial Magistrate, Bilaspur under Section 164 of Criminal Procedure Code.

Trial and Conviction by the Sessions Court

Following the investigation, the police filed a chargesheet. During the trial, the prosecution examined 21 witnesses. The accused pleaded not guilty but did not lead any defence evidence. Based on the evidence presented, the Sessions Court convicted Sanjay Kumar and sentenced him to seven years of rigorous imprisonment and imposing a fine of Rs. 20,000. The Court also sentenced Chaman Shukla to one year of simple imprisonment.

High Court's Acquittal and Present Appeals

Aggrieved by their convictions, both accused filed appeals before the High Court. The High Court acquitted them of all charges and allowed their appeals. The State has now preferred these appeals against the judgment of acquittal.

State of Himachal Pradesh vs Sanjay Kumar 2025 Legal Issues

The following issues were also addressed in State of Himachal Pradesh vs Sanjay Kumar 2025:

1. Reliability of Prosecutrix’s Testimony

The main issue was whether the only testimony of the prosecutrix with internal contradictions and inconsistencies could be the basis for convicting the accused for the offence of rape. The Court examined whether her statements inspired confidence and whether they could stand without strong corroborative evidence.

2. Material Contradictions in Statements

The Supreme Court in State of Himachal Pradesh vs Sanjay Kumar analysed whether the inconsistencies in the prosecutrix’s version particularly regarding the date, place and manner of the alleged sexual assault were material enough to affect the credibility of the case of the prosecution.

3. Requirement of Corroborative Evidence

The Court acknowledged the importance of supporting evidence such as DNA analysis, mobile phone tracking and corroborative witness testimony (especially from PW-6/Jawala Devi) to substantiate the allegations of rape and abduction.

4. Failure to Prove Rape Beyond Reasonable Doubt

Another important issue in State of Himachal Pradesh vs Sanjay Kumar was whether the prosecution was able to prove beyond reasonable doubt that accused Sanjay Kumar had committed rape especially when medical evidence did not conclusively establish the accused’s involvement and when key witnesses did not support the prosecution story.

Section 164 of Criminal Procedure Code played an important role in State of Himachal Pradesh vs Sanjay Kumar 2025. The following is the analysis of this provision:

Section 164 of Criminal Procedure Code, 1973

Section 164 CrPC (Now Section 183 of Bharatiya Nagarik Suraksha Sanhita 2023) empowers a Judicial Magistrate to record confessions or statements made voluntarily during the course of investigation. It aims to ensure that such statements are made without coercion and can be relied upon during trial. The provision is important because in State of Himachal Pradesh vs Sanjay Kumar, the statements of the prosecutrix recorded under Section 164 CrPC were scrutinized during trial and appellate review.

State of Himachal Pradesh vs Sanjay Kumar 2025 Judgment and Impact

On 23rd April, 2025, the Supreme Court of India in State of Himachal Pradesh vs Sanjay Kumar after thoroughly examining the evidence on record and hearing arguments from both sides, the Court concluded that the decision of the High Court to acquit the accused Sanjay Kumar and Chaman Shukla was justified.

The Appellant-State relied mainly on the statement of the prosecutrix and claimed that it was credible and sufficient for conviction. However, the Respondents contended that the prosecutrix had left voluntarily and pointed out major inconsistencies in her statements regarding the date, place and circumstances of the alleged rape. They also highlighted the lack of corroborative evidence including the absence of DNA analysis and supportive witness testimony from PW-6, in whose house the alleged offence occurred.

The Supreme Court in State of Himachal Pradesh vs Sanjay Kumar observed significant contradictions in the prosecutrix's narrative especially about when and where the rape allegedly took place. It noted that the prosecutrix made inconsistent claims:

First stating under Section 164 of Criminal Procedure Code that the rape occurred on 31st March, 2012 at Chaman Shukla's house and later asserted in court that it happened on 30th March, 2012 at Jawala Devi's house. Moreover, there was no direct evidence to confirm that Sanjay Kumar was present at Rampur on the night of the alleged incident.

The Court in State of Himachal Pradesh vs Sanjay Kumar also observed that although medical evidence suggested the possibility of rape but it did not establish the identity of the perpetrator, especially since no DNA testing was conducted. Further, the prosecutrix did not inform anyone immediately after the incident, weakening the prosecution’s case.

On the basis of the above findings, the Supreme Court held that the ruling of the High Court were based on a plausible and reasonable interpretation of the facts. Therefore, no interference with the acquittal was warranted. Accordingly, the appeals in Himachal Pradesh vs Sanjay Kumar challenging the acquittal of Sanjay Kumar and Chaman Shukla were dismissed.

Conclusion

The landmark judgement State of Himachal Pradesh vs Sanjay Kumar 2025 the Supreme Court on 23rd April, 2025 upheld the acquittal awarded by the High Court. The Court highlighted that the Prosecution failed to prove the guilt of the accused beyond reasonable doubt due to material contradictions in the prosecutrix's statements and lack of supporting evidence. The judgment reaffirmed that courts must maintain a high standard of proof in criminal cases, particularly when life and liberty are at stake.