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Madras High Court· 11 September 2026

Is the sole testimony of the victim sufficient to convict an accused where that testimony is of sterling quality?

KURALARASAN v. STATE REP BY
CRL A.473/2022 · 2026:MHC:3758 · CRL A No. 473 of 2022
Coram: Justice G.Arul Murugan
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Answer

The sole testimony of the victim is sufficient to convict an accused where that testimony is of sterling quality.

Yes. The sole testimony of the victim is sufficient to convict an accused where that testimony is of sterling quality and inspires the confidence of the Court. Where the victim's evidence is clear, unambiguous and trustworthy, withstands cross-examination and is corroborated by the medical evidence and records, no further corroboration is required for recording a conviction.

Headnote

Protection of Children from Sexual Offences Act, 2012 — ss.5(l), 6, 29 — Indian Penal Code, 1860 — s.366 — Age of the victim — Consent immaterial — Sole testimony of the victim — Delay in lodging the complaint — Statutory presumption — Protection of Children from Sexual Offences Act, 2012 — Minor victim — Consent — Held: Once it is established that the victim was a minor, the question of consent becomes insignificant. (¶32) Evidence — Sole testimony of the victim — Held further: The sole testimony of the victim is sufficient to convict an accused where that testimony is of sterling quality and inspires the confidence of the Court. (¶27, 28) Criminal law — Sexual offences — Delay in lodging the complaint — Held further: Mere delay in lodging the complaint in a sexual offence case is not by itself fatal to the prosecution where the delay is properly explained. (¶30) Protection of Children from Sexual Offences Act, 2012 — s.29 — Statutory presumption — Held further: The statutory presumption under s.29 of the Protection of Children from Sexual Offences Act, 2012 operates once the prosecution establishes the foundational facts. (¶33) Conviction and sentence confirmed; appeal dismissed. (¶34, 35)

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In the Court's own words
Paragraph 27It is well settled that even the sole testimony of the victim is sufficient to convict an accused, provided such testimony is of sterling quality and inspires the confidence of the Court. In this regard it is useful to refer to the decision of the Three Judge Bench of the Hon’ble Supreme Court in Ganesan vs. State, Represented by the Inspector of Police[^1], wherein it has been held that, when the sole testimony of the victim is reliable and trustworthy, no further corroboration is required for recording a conviction, and the relevant portions are as follows:
Paragraph 28The evidence of PW1, regarding the sexual intercourse had by the accused on several occasions by forcefully taking her away and threatening to commit suicide, is clear, unambiguous, and trustworthy. PW1 withstood the cross-examination and her testimony is unblemished, trustworthy and inspires the confidence of the Court. Further, the evidence of the Doctors/PW5 and PW6 coupled with the medical reports in the Ex.P6 and Ex.P7 as well as Ex.P1, corroborates the version of PW1 and establishes the sexual relationship had by the accused on several occasions when the victim was a minor.
Acts & Sections
s.5(l) Protection of Children from Sexual Offences Act, 2012s.6 Protection of Children from Sexual Offences Act, 2012s.29 Protection of Children from Sexual Offences Act, 2012s.366 Indian Penal Code, 1860s.164 Code of Criminal Procedure, 1973

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Also decided in this judgment
Is the question of consent insignificant once it is established that the victim was a minor?Is mere delay in lodging the complaint in a sexual offence case fatal to the prosecution where the delay is properly explained?Does the statutory presumption under s.29 of the Protection of Children from Sexual Offences Act, 2012 operate once the foundational facts are established?
Plain-language answer prepared by the LexStreak Editorial Desk — verify against the judgment. Source: Madras High Court. Corrections