In a significant judgment clarifying the evidentiary value of DNA reports in sexual offence cases, the Tripura High Court has held that a negative DNA result cannot automatically negate allegations of rape. The Court observed that while such a report may disprove paternity of a child, it does not by itself absolve an accused from criminal liability for rape if other reliable evidence supports the prosecution’s case.
The ruling came from a Division Bench comprising Justice T. Amarnath Goud and Justice S. Datta Purkayastha, which upheld the conviction of the main accused under Sections 376(2)(n) and 506 of the Indian Penal Code (IPC) along with Section 6 of the Protection of Children from Sexual Offences (POCSO) Act, 2012. The Bench maintained the sentence of rigorous life imprisonment for 20 years, emphasizing that the victim’s testimony and surrounding circumstances formed a strong foundation for conviction.
Background of the Case
The case originated from a complaint lodged by a minor girl on February 26, 2021. According to the prosecution, the victim alleged that approximately a year prior to the complaint, she had gone to the house of the accused, who was her neighbour, where she was subjected to forceful sexual intercourse.
During the course of events, the victim became pregnant, which led to further developments including allegations that money was paid for an abortion and that a temple marriage later took place between the accused and the victim. These circumstances were considered relevant by the prosecution to establish the conduct and involvement of the accused.
Following trial proceedings, the lower court convicted the main accused for repeated rape and criminal intimidation, along with offences under the POCSO Act. The matter subsequently reached the Tripura High Court through an appeal challenging the conviction.
Central Issue: Impact of Negative DNA Report
One of the principal arguments raised by the defence was based on the DNA test results. The report indicated a mismatch, suggesting that the accused was not the biological father of the child. The defence argued that this forensic finding should weaken the prosecution’s case and raise serious doubts about the allegations.
However, the High Court rejected this contention. The Bench clarified that a negative DNA result can only be relevant to determining paternity and cannot automatically negate the occurrence of sexual assault. The Court explained that rape as an offence is not dependent solely on the existence or proof of pregnancy or biological lineage.
By drawing this distinction, the Court underscored that forensic evidence is only one component of the evidentiary framework and must be assessed alongside oral testimony and surrounding circumstances.
Reliance on Victim’s Testimony
A crucial aspect of the Court’s reasoning was its reliance on the testimony of the prosecutrix. The Bench observed that the victim’s account remained consistent and credible throughout the proceedings. Indian criminal jurisprudence has long recognised that the sole testimony of a victim can be sufficient to sustain a conviction if it inspires confidence.
The Court also pointed to corroborative circumstances, including the behaviour of the accused and his family, the alleged financial assistance for abortion, and the subsequent temple marriage between the accused and the victim. These factors, according to the Bench, lent further support to the prosecution’s narrative.
The judgment reiterates a well-settled legal principle — that courts must evaluate the totality of evidence rather than rely exclusively on scientific reports.
Conviction Upheld for Main Accused
After examining the evidence, the High Court affirmed the conviction of the primary accused under:
- Section 376(2)(n) IPC – repeated rape,
- Section 506 IPC – criminal intimidation, and
- Section 6 of the POCSO Act – aggravated penetrative sexual assault.
The Court upheld the rigorous life imprisonment of 20 years imposed by the trial court, finding no reason to interfere with the sentence. The Bench emphasised that offences under the POCSO Act demand a sensitive and comprehensive evaluation of evidence, keeping in mind the vulnerability of minor victims.
Acquittal of Co-Accused
While upholding the conviction of the main accused, the High Court adopted a different approach regarding the co-accused, who was the younger brother of the primary accused. The Bench noted “abnormal discrepancies” in the prosecution’s case against him and found that the evidence did not meet the threshold required for sustaining a conviction.
Consequently, the Court set aside the conviction of the co-accused, reinforcing the principle that criminal liability must be determined individually based on the specific role and evidence against each person.
This part of the ruling demonstrates the Court’s balanced approach — ensuring justice for the victim while preventing wrongful conviction where evidence is insufficient.
Legal Significance of the Judgment
The Tripura High Court’s decision is significant for several reasons:
1. Clarification on Forensic Evidence
The judgment makes it clear that DNA reports, though valuable, are not conclusive in determining the occurrence of rape. Courts must consider the broader evidentiary landscape rather than treating scientific findings as determinative.
2. Strengthening Victim-Centric Jurisprudence
By affirming that credible testimony of the prosecutrix can sustain a conviction, the ruling reinforces victim-centric principles embedded in Indian criminal law and POCSO jurisprudence.
3. Individualised Assessment of Accused
The acquittal of the co-accused underscores the judiciary’s obligation to evaluate evidence separately against each accused, preventing blanket convictions.
4. Emphasis on Circumstantial Evidence
The Court’s reliance on surrounding circumstances — such as alleged conduct after the incident — highlights how behavioural evidence can play a critical role in sexual offence cases.
Broader Implications for Sexual Offence Trials
The decision contributes to ongoing legal discourse about the role of forensic science in criminal trials. While DNA evidence is often viewed as highly reliable, this judgment reiterates that it cannot replace judicial evaluation of human testimony and contextual factors.
In many sexual offence cases, especially those involving minors, delays in reporting or medical examination may affect forensic findings. The High Court’s reasoning acknowledges this reality and ensures that victims are not denied justice solely due to absence of biological linkage.
The ruling may also serve as persuasive precedent in future cases where defence arguments rely heavily on negative DNA reports to challenge rape allegations.
Conclusion
The Tripura High Court’s ruling that a negative DNA report disproves paternity but not rape marks an important clarification in Indian criminal jurisprudence. By upholding the POCSO conviction of the main accused while acquitting the co-accused due to lack of evidence, the Court struck a careful balance between safeguarding victims’ rights and ensuring fairness in criminal trials.
The judgment reinforces that courts must evaluate evidence holistically, giving due weight to the victim’s testimony and surrounding circumstances rather than relying solely on forensic outcomes. As debates around the evidentiary role of DNA continue to evolve, this decision stands as a reminder that justice in sexual offence cases rests on the totality of proof — not on a single scientific report alone.
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