The State of Rajasthan vs Chatra: Supreme Court Case

The State of Rajasthan vs Chatra 2025 case drew attention after the Supreme Court condemned the Rajasthan High Court for acquitting the accused on the flawed ground that the victim did not verbally testify. The Apex Court stressed that a child’s silence particularly due to trauma must not be misinterpreted as lack of evidence when other supporting proof exists. Discover more in-depth analyses of important Supreme Court decisions by exploring Recent Judgements of Supreme Court.

The State of Rajasthan vs Chatra 2025 Introduction

State of Rajasthan vs Chatra (2025) centres around the rape of a minor girl in 1986. The Trial Court convicted the accused based on medical and circumstantial evidence under Section 376 of Indian Penal Code. However in 2013 the Rajasthan High Court overturned the conviction because the child victim remained silent and wept during her cross-examination.

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The case at hand centres around the rape of a minor girl that occurred in 1986 where the accused was convicted by the Trial Court under Section 376 of Indian Penal Code. However, in 2013 Rajasthan High Court reversed the conviction only on the ground that the child victim had remained silent and shed tears during her cross-examination. The following are facts of State of Rajasthan vs Chatra -

• Incident Date: The incident of rape occurred in 1986 involving the rape of a minor girl by the Respondent-Accused.
• Trial Court Conviction: The Trial Court convicted the accused under Section 376 of Indian Penal Code based on medical and circumstantial evidence.
• Appeal Before the High Court: Aggrieved by the decision of the lower court the accused filed an appeal in 1987 before the Rajasthan High Court challenging the conviction. However, the High Court delayed the decision and only delivered its judgment in 2013 i.e., 26 years after the appeal was filed.
• High Court Decision: The Rajasthan High Court set aside the conviction on the ground that the Prosecutrix (minor victim) remained silent and only cried during her cross-examination.
• Supreme Court Intervention: The State appealed against the decision of the Rajasthan High Court before the Supreme Court. A Bench comprising Justice Vikram Nath and Justice Sanjay Karol took up the matter.

The State of Rajasthan vs Chatra 2025 Legal Issues

The main issues which was addressed in the State of Rajasthan vs Chatra was whether the silence of a child victim during cross-examination manifested only through tears and no verbal testimony can be treated as a ground to acquit the accused in a rape case?

The case also considered sub-issues which are as follows -

• Whether the absence of direct testimony from the Prosecutrix (due to trauma) is fatal to the case of Prosecution?
• Whether the High Court erred in setting aside conviction awarded by the Trial Court?

Section 376 of Indian Penal Code, Section 118 of Indian Evidence Act and Article 21 of Indian Constitution played an important role in The State of Rajasthan vs Chatra. The following are analysis of these provisions 

Section 376 of Indian Penal Code

Section 376 (Now Section 64 of Bharatiya Nyaya Sanhita 2023) deals with the offence of rape. At the time of the incident (1986), Section 376 provided punishment for rape, including rigorous imprisonment of not less than seven years, which may extend to life imprisonment, along with fine.

Section 118 of Indian Evidence Act

Section 118 (Now Section 124 of Bharatiya Sakshya Adhiniyam 2023) deals with the competency of witnesses including children provided they are able to understand the questions and give rational answers. 

Article 21 of Indian Constitution: Protection of life and personal liberty

Article 21 under Part III of Indian Constitution states no person can be deprived of life or personal liberty except in accordance with procedure established by law.

The State of Rajasthan vs Chatra 2025 Judgment and Impact

On 18th March, 2025 the Supreme Court in the State of Rajasthan vs Chatra allowed the appeal filed by State and restored the conviction and sentence of the accused to 7 years of imprisonment under Section 376 of Indian Penal Code. 

The 2-Judge Bench of the Supreme Court comprising Justice Vikram Nath and Justice Sanjay Karol strongly condemned the Rajasthan High Court for setting aside the conviction only because the child victim remained silent and shed tears during cross-examination.

The Bench led by Justice Vikram Nath in the State of Rajasthan vs Chatra held that the silence of a traumatised child cannot be treated as a ground for acquittal especially when other medical and circumstantial evidence supports the case of the Prosecution. 

The Court observed that the tears of the victim must be understood in the context of trauma and her silence does not absolve the accused of guilt. The Supreme Court reprimanded the High Court for disclosing the identity of the minor victim in its judgment which infringed her right to privacy and dignity. 

Given the long delay in the judicial process in the State of Rajasthan vs Chatra with the offence occurring in 1986 and the High Court deciding the appeal only in 2013 the Supreme Court chose not to remand the matter and instead decided the case based on the available evidence.

Thus the Supreme Court in the State of Rajasthan vs Chatra ruled that justice should not be denied due to a child’s inability to verbalise traumatic experiences and conviction can stand in the absence of direct testimony if the overall evidence is credible and consistent.

Conclusion

In State of Rajasthan vs Chatra 2025 the Supreme Court restored the conviction and sentenced the accused to seven years of imprisonment. It held that the trauma induced silence of a minor cannot become the basis for acquittal especially when credible medical and circumstantial evidence is available.