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Mohd. Iqbal M. Shaikh & Ors vs The State Of Maharashtra on 15 April, 1998

In Mohd. Iqbal's case (supra), a learned Single Bench of this court has indeed released on bail a police personnel facing trial for commission of offence under section 372 (2) (a) RPC for allegedly having committed rape on a lady, who was in his custody during investigation of a case. The judgment rendered by the learned Bench, however, cannot be applied in the fact situation of the case on hand for the simple reason that in that case one of the grounds B.A. No. 63/2017 Page 5 of 11 6 on which bail was sought was that the prosecutrix had not supported the case of the prosecution in her deposition before the trial court and rather had denied the allegation of rape on her by the accused and stated also that she was compelled to lodge the report against the accused therein by the SDPO and a lady Police Officer. In granting the bail, learned Bench, amongst other reasons, noticed that the prosecutrix has not given statement according to the prosecution story. There is another reason for which the judgment rendered by the learned Single Bench could not have been followed without considering the legal position arising pursuant to the amendment to the Cr.P.C and the RPC by the Jammu and Kashmir Criminal Laws (Amendment) Act, 2013 (for short the Amendment Act of 2013), which it appears has not attracted consideration of the learned Bench in that case.
Supreme Court of India Cites 19 - Cited by 116 - Full Document

Aslam vs State Of U.P on 13 February, 2013

12. In order to surpass the rigor of the restriction contemplated under proviso section 497-C Cr.P.C. the main plank of petitioners' case is that the evidence given by the prosecutrix in the trial court read in light of the evidence of the doctor, PW-Dr. Shafika Bano, does not prove commission of offence of rape on the prosecutrix by the petitioners. It is contended that the prosecutrix has falsely implicated them at the behest of a person against whom petitioner No.2 is a prosecution witness in a case under section 366/376 RPC. The said person, however, has not been named in the bail application nor does any B.A. No. 63/2017 Page 9 of 11 10 such suggestion seem to have been made to the prosecutrix in her cross-examination by the defence. It would, however, not be proper to discuss in detail or give any indication about the incriminating value of the testimony of the prosecutrix recorded by the trial court lest that may prejudice the defence of the petitioners at the trial of the case. The least that can be said is that the prosecutrix has deposed in line with the prosecution case and has not exonerated the petitioners directly or by implication. The evidentiary value of the evidence of prosecutrix in a case of rape is too well known and is governed by well settled legal principles (see Aslam v State of U. P. (2014)13 SCC 350 and Hem Raj v State of Haryana, (2014) 2 SCC 395). The judgment in Raja and ors. (supra) relied upon on behalf of the petitioners cannot be applied in a bail application as the same is based on the analysis of the evidence of the prosecutrix at final judgment stage and it is too well known that criteria of appreciating the evidence/material at bail stage is different than the criteria at the final judgment stage.
Supreme Court of India Cites 7 - Cited by 4 - Full Document
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