'False Rape Accusations Not Uncommon': Rajasthan High Court Acquits Convict Citing Animosity Between Parties, Lack Of Medical Evidence

Setting aside the Trial Court's order, Rajasthan High Court acquitted a rape convict, opining that since false accusations were not uncommon, judiciary had to exercise prudence and discernment, particularly in cases involving serious allegations like rape. It was held that such charges may be motivated by motives like revenge, extortion or evasion of financial obligations.

The bench of Justice Manoj Kumar Garg gave this ruling in the background of lack of corroboration of prosecutrix's testimony from scientific and medical evidence, non-production of FSL report, as well as delay of 3 days in lodging the FIR which was stated as being indicative of a fabricated or exaggerated story.

“The inherent improbability of the prosecutrix's version, combined with the consistent admissions of violence from both sides and the corroborative medical evidence supporting the appellant's account, suggest a likelihood that the case has been falsely fabricated. It is plausible that the prosecutrix and her husband may have lodged a false complaint to settle personal scores or for ulterior motives.”

The appellant was charged in a case of rape wherein he was convicted by the Trial Court. Appeal was preferred against the order of the Trial Court claiming that a false case was fabricated against him.

It was argued that the FIR was filed after a delay of 3 days without providing any satisfactory explanation. Further, it was alleged that the prosecutrix's husband had animosity towards the appellant, and hence, after assaulting him along with her husband, the prosecutrix lodged a false FIR.

After hearing the contentions, the Court perused the records and highlighted that, firstly, as per the testimonies there was heated altercation involving physical violence between the parties. Secondly, as per the medical officer, even though there were abrasions on the prosecutrix's back and injuries of other parts of her body, no seminal fluid or blood stains were found on her clothing.

The court further highlighted that failure on her part to produce any FSL report that could have provided scientific validation to her claim, significantly undermined her credibility. Finally, it was also stated that the unexplained delay of 3 days in filing of the FIR was often indicative of a fabricated and exaggerated story.

In this background, the Court opined that there were serious doubts on the prosecution's case, and that there was a plausibility that the prosecutrix lodged a false complaint with her husband to settle personal scores or ulterior motives.

It was opined that no case against the appellant was established beyond reasonable doubt, and observed that,

“this Court opines that judiciary must exercise prudence and discernment, particularly in cases involving serious allegations such as rape, recognizing that false accusations are not uncommon Such charges may be motivated by motives such as revenge, extortion, or the desire to evade financial obligations. Therefore, the determination of whether an act of rape has occurred must be based on a thorough examination of the specific facts and circumstances unique to each case.”

Accordingly, the appeal was allowed, setting aside conviction of the appellant and acquitting him from the charges of rape.

Title: Khema v State of Rajasthan

Citation: 2025 LiveLaw (Raj) 177

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