Is Police Evidence Admissible in Court? Insights from Uttarakhand High Court's POCSO Bail Order

Introduction – The Legal Context of Police Evidence in Indian Criminal Law

The question of whether police evidence is admissible in court is fundamental to the administration of criminal justice in India. Police officers are often the first responders to crime scenes, the primary investigators of criminal offences, and key witnesses in prosecutions. Their testimony, the evidence they collect, and the investigation they conduct form the backbone of most criminal cases in India. However, the admissibility and evidentiary value of police evidence have been subjects of considerable judicial scrutiny and legislative regulation.

Under the Indian Evidence Act, 1872, police evidence is generally admissible, but it is subject to certain limitations and safeguards. Section 25 of the Evidence Act explicitly prohibits confessions made to police officers from being proved against the accused. This provision reflects a deep-seated concern about the potential for coercion and abuse of power during police custody. Similarly, Section 26 bars confessions made in police custody unless made in the immediate presence of a magistrate. These provisions underscore the legislature's recognition that police evidence, particularly statements obtained during investigation, must be treated with caution.

The testimony of police officers as witnesses, however, is admissible under the general provisions of the Evidence Act. Police officers can testify about facts they have personally observed, evidence they have collected, and the results of their investigation. Their testimony is evaluated like that of any other witness, though courts have consistently held that police testimony should be scrutinized carefully, particularly when it is the sole basis for conviction. The Supreme Court has repeatedly emphasized that while police officers are competent witnesses, their evidence should be corroborated by independent evidence, especially in cases involving serious offences.

The recent judgment of the Uttarakhand High Court in *Rampal v. State of Uttarakhand* (Criminal Appeal No. 100 of 2024) brings these principles into sharp focus. The case involved allegations under the Protection of Children from Sexual Offences (POCSO) Act, 2012, where the accused was convicted by the trial court primarily on the basis of police investigation. However, the High Court found that the conviction was based on insufficient evidence and granted bail to the accused, suspending the conviction pending appeal. This judgment raises important questions about the quality of police investigation, the sufficiency of evidence required for conviction, and the role of appellate courts in scrutinizing trial court judgments.

The POCSO Act was enacted to provide stringent punishment for sexual offences against children and to establish special procedures for the trial of such cases. The Act creates a presumption of guilt in certain circumstances and places the burden on the accused to prove innocence. However, this does not mean that the prosecution is relieved of its duty to prove the case beyond reasonable doubt. The foundational principle of criminal jurisprudence—that the accused is presumed innocent until proven guilty—remains sacrosanct even in POCSO cases.

The Uttarakhand High Court's judgment is significant because it demonstrates that even in cases involving serious allegations against children, courts will not uphold convictions that are based on inadequate or unreliable evidence. The judgment emphasizes that the gravity of the offence cannot justify a departure from established principles of evidence and criminal procedure. It also highlights the importance of forensic evidence, medical examination, and independent corroboration in cases involving sexual offences.

This blog post examines the Uttarakhand High Court's judgment in detail, analyzing the court's reasoning, the legal principles it applied, and the broader implications for criminal justice administration in India. We will explore the role of police evidence in criminal trials, the standards of proof required for conviction, and the safeguards that exist to prevent wrongful convictions. We will also consider the practical challenges faced by investigating agencies and trial courts in handling sensitive cases involving children, and the need for better training, resources, and forensic support.

Case Background – Facts, Parties, and Legal Questions

The case of *Rampal v. State of Uttarakhand* arose from allegations of kidnapping and sexual assault of a minor girl. The complainant was the father of the victim, who alleged that his daughter had left home on January 10, 2022, stating that she was going to her grandfather's house. When she did not return, the father became concerned and suspected that she had absconded with the appellant/applicant, Rampal.

The jurisdictional police registered a First Information Report (FIR) and commenced an investigation into the matter. The investigation revealed that the victim was found in the company of the accused on January 23, 2022, near Arakot Bazar Bridge. The accused was arrested, and the victim was taken for medical examination. The investigating officer obtained a birth certificate from the victim's school to establish her age, which confirmed that she was a minor at the time of the alleged offence.

Based on the investigation, a charge-sheet was filed against the appellant/applicant under Sections 363 (kidnapping) and 376(2)(n) (rape of a woman under sixteen years of age) of the Indian Penal Code, 1860, and Section 5(l) of the POCSO Act, which deals with aggravated penetrative sexual assault. Section 5 of the POCSO Act prescribes enhanced punishment for penetrative sexual assault committed in certain aggravating circumstances, such as when the victim is below twelve years of age, or when the assault is committed by a person in a position of trust or authority.

The case proceeded to trial before the Special Sessions Judge, Uttarkashi, who convicted the accused and sentenced him to imprisonment. The trial court's judgment was based primarily on the evidence collected by the police during the investigation, including the victim's initial statement, the medical examination report, and the forensic science laboratory (FSL) report on the victim's clothing.

However, during the trial, the victim turned hostile and denied that the accused had committed any wrongdoing. She testified that she had gone with the accused voluntarily and that no sexual assault had taken place. Despite this, the trial court relied on the victim's earlier statement recorded during the investigation and convicted the accused. The trial court also relied on the FSL report, which indicated the presence of human semen on the victim's innerwear.

Aggrieved by the conviction, the accused filed a criminal appeal before the Uttarakhand High Court. The appeal was heard by a Division Bench comprising Chief Justice G. Narendar and Justice Alok Mahra. The appellant was represented by Advocate Priyanshu Gairola, while the State was represented by Deputy Advocate General J.S. Virk.

During the hearing of the appeal, a significant development occurred. The victim herself appeared before the High Court and pleaded for the release of the accused. She stated that she was working as a housemaid and that the accused was her husband. She further stated that she was undergoing trauma on account of the application of the law and the judgment of conviction passed by the trial court. This statement by the victim was a crucial factor in the High Court's consideration of the case.

The High Court examined the evidence on record and identified several serious deficiencies in the prosecution's case. First, the court noted that there was no evidence regarding the place where the alleged offence was committed. The victim was found with the accused near Arakot Bazar Bridge, but there was no evidence about where they had stayed during the period between January 10 and January 23, 2022. The prosecution had not produced any evidence of a residential house, hotel accommodation, or any other location where the alleged sexual assault could have taken place.

Second, the medical examination of the victim did not support the allegation of sexual assault. The medical expert who examined the victim recorded that there was no sign of injury anywhere on her body or private parts. There were no injury marks, no swelling, bruises, or cuts on or around the genitals. The doctor opined that there were no signs of any forceful sexual assault. This medical evidence was inconsistent with the charge of aggravated penetrative sexual assault under Section 5 of the POCSO Act.

Third, the forensic evidence was inconclusive. While the FSL report indicated the presence of human semen on the victim's innerwear, it did not establish that the semen belonged to the accused. The prosecution had not conducted a DNA test to link the semen to the accused, and therefore, the forensic evidence did not conclusively prove that the accused had committed the offence.

Fourth, the victim had turned hostile during the trial and denied the allegations against the accused. While the trial court had relied on the victim's earlier statement, the High Court found it problematic that the trial court had placed reliance on a statement that was not marked as an exhibit and was not made part of the record. The High Court noted that despite detailed cross-examination, nothing incriminating against the accused had been elicited from the victim's testimony.

Based on these observations, the High Court concluded that the trial court's judgment of conviction was unsustainable. The court characterized the case as one of "no evidence at all" rather than merely insufficient evidence. The High Court held that in the absence of critical evidence relating to the place of commission of the offence, or any forensic evidence linking the accused to the crime, the judgment of conviction was "more than shocking."

The legal questions that arose in this case were: (1) What is the standard of proof required for conviction in a POCSO case? (2) Can a conviction be sustained solely on the basis of police investigation without independent corroboration? (3) What is the evidentiary value of a victim's statement when the victim subsequently turns hostile? (4) What role does forensic evidence play in establishing guilt in sexual assault cases? (5) Can a conviction under Section 5 of the POCSO Act be sustained in the absence of evidence of penetrative sexual assault?

Court's Observations – Legal Reasoning and Judicial Analysis

The Uttarakhand High Court's judgment in *Rampal v. State of Uttarakhand* is a significant contribution to the jurisprudence on evidence in criminal cases, particularly in cases involving sexual offences against children. The court's observations reflect a careful application of established principles of criminal law and evidence, and a willingness to scrutinize trial court judgments to prevent miscarriage of justice.

The High Court began its analysis by noting that the case was not one of insufficient evidence, but rather "a case of no evidence at all." This characterization is important because it indicates that the court found fundamental deficiencies in the prosecution's case that went beyond mere weaknesses or gaps in the evidence. The court observed that the victim was missing between January 10, 2022, and January 23, 2022, and was found in the company of the accused near Arakot Bazar Bridge. However, the prosecution had failed to establish where the alleged offence was committed during this period.

The court emphasized that the place of occurrence is a critical element in any criminal prosecution. In cases involving sexual offences, the prosecution must prove not only that the offence occurred, but also where it occurred. This is important for several reasons. First, it helps to establish the jurisdiction of the court. Second, it allows the accused to prepare a defense by providing specific details about the alleged incident. Third, it enables the investigation to focus on collecting evidence from the scene of the crime, such as forensic evidence, witness statements, and other material evidence.

In this case, the trial court's judgment did not record any proof of the place of residence or the location where the alleged sexual assault took place. There was no evidence of a residential house, hotel accommodation, or any other location that could be identified as the scene of the crime. The High Court found this omission to be fatal to the prosecution's case, as it meant that the conviction was based on speculation rather than concrete evidence.

The High Court also examined the medical evidence in detail. The medical examination of the victim is a crucial piece of evidence in sexual assault cases, as it can provide objective, scientific evidence of the alleged assault. In this case, the medical expert who examined the victim found no signs of injury on her body or private parts. There were no injury marks, no swelling, bruises, or cuts on or around the genitals. The doctor opined that there were no signs of any forceful sexual assault.

The High Court noted that this medical evidence was inconsistent with the charge of aggravated penetrative sexual assault under Section 5 of the POCSO Act. Section 5 deals with aggravated forms of penetrative sexual assault, which typically involve more serious forms of sexual violence. The absence of any physical signs of assault raised serious doubts about whether any penetrative sexual assault had occurred at all. The court observed that "prima facie, the finding of guilt, under Section 5(l), in the absence of any evidence to even demonstrate penetrative sexual assault, is unsustainable."

This observation is significant because it underscores the importance of medical evidence in sexual assault cases. While the absence of physical injuries does not necessarily mean that no sexual assault occurred—as sexual assault can occur without leaving physical marks—the complete absence of any physical evidence, combined with other deficiencies in the prosecution's case, raised serious doubts about the reliability of the conviction.

The High Court also examined the forensic evidence, specifically the FSL report on the victim's innerwear. The FSL report indicated the presence of human semen on the victim's innerwear, which the prosecution relied upon to establish that sexual intercourse had occurred. However, the High Court noted a critical deficiency in the forensic evidence: the FSL report did not establish that the semen belonged to the accused. The court observed: "Even more surprising is the finding of the FSL, that has recorded an opinion, that traces of 'human semen' are found on the Exhibit-3, i.e. the innerwear of the victim. There is no finding by the FSL that the traces of semen found on Exhibit-3 (FSL Report) is that of the appellant/applicant."

This observation highlights the importance of DNA testing in sexual assault cases. The mere presence of semen on the victim's clothing does not, by itself, establish that the accused committed the offence. To link the accused to the crime, the prosecution must conduct a DNA test to match the semen to the accused. In the absence of such testing, the forensic evidence is inconclusive and cannot form the basis for a conviction.

The High Court also addressed the issue of the victim's testimony. During the trial, the victim turned hostile and denied that the accused had committed any wrongdoing. She testified that she had gone with the accused voluntarily and that no sexual assault had taken place. Despite this, the trial court relied on the victim's earlier statement recorded during the investigation and convicted the accused.

The High Court found this approach problematic. The court noted that the victim's earlier statement was not marked as an exhibit and was not made part of the record. Despite this, the trial court had placed reliance on the statement. The High Court stated: "Though, the victim has been subjected to detailed cross-examination, nothing incriminating against the appellant has been elicited. Despite the statement, not being marked as an exhibit, and not being made part of the record, we find it strange that the Trial Court has placed reliance on the same."

This observation raises important questions about the evidentiary value of statements recorded during investigation when the witness subsequently turns hostile. Under Section 145 of the Evidence Act, a witness may be cross-examined on previous statements to impeach their credit. However, the previous statement cannot be used as substantive evidence of the facts stated therein unless it falls within certain exceptions, such as statements made under Section 157 (to corroborate testimony) or Section 162 of the Criminal Procedure Code (statements to police, which can be used for contradiction but not as substantive evidence).

In this case, the trial court appears to have relied on the victim's earlier statement as substantive evidence of the accused's guilt, despite the fact that the victim had turned hostile and denied the allegations. The High Court found this approach to be legally unsound, as it violated established principles of evidence law.

The High Court's judgment also reflects a broader concern about the quality of police investigation and the role of trial courts in scrutinizing evidence. The court observed that the trial court had failed to critically examine the evidence and had convicted the accused despite serious deficiencies in the prosecution's case. The court's characterization of the conviction as "more than shocking" indicates its strong disapproval of the trial court's approach.

From a legal perspective, the High Court's judgment is significant because it reaffirms the principle that the burden of proof in criminal cases rests on the prosecution, and that the accused is entitled to the benefit of the doubt when the evidence is insufficient or unreliable. The judgment also emphasizes the importance of forensic evidence, medical examination, and independent corroboration in cases involving sexual offences. It serves as a reminder that the gravity of the offence cannot justify a departure from established principles of evidence and criminal procedure.

Impact – Broader Legal and Practical Implications

The Uttarakhand High Court's judgment in *Rampal v. State of Uttarakhand* has significant implications for the administration of criminal justice in India, particularly in cases involving sexual offences against children. The judgment raises important questions about the quality of police investigation, the standards of proof required for conviction, and the role of appellate courts in preventing miscarriage of justice.

One of the most important implications of the judgment is its emphasis on the need for thorough and professional police investigation. The High Court's criticism of the investigation in this case—particularly the failure to establish the place of occurrence, the lack of forensic evidence linking the accused to the crime, and the reliance on inconclusive medical evidence—highlights the importance of proper investigative procedures. Police officers investigating sexual offences must be trained to collect and preserve evidence in a manner that meets legal standards and can withstand judicial scrutiny.

The judgment also underscores the importance of forensic evidence in sexual assault cases. The High Court's observation that the FSL report did not establish that the semen found on the victim's innerwear belonged to the accused highlights the need for DNA testing in such cases. DNA evidence is one of the most reliable forms of forensic evidence and can provide conclusive proof of the identity of the perpetrator. However, DNA testing is not always conducted in sexual assault cases, either due to lack of resources, inadequate training, or procedural lapses. This judgment serves as a reminder that forensic evidence must be collected and analyzed properly to ensure that convictions are based on reliable scientific evidence.

The judgment also has implications for the role of medical examination in sexual assault cases. The High Court's observation that the medical examination did not reveal any signs of forceful sexual assault raises questions about the evidentiary value of medical reports. While medical evidence is important, it is not always conclusive, as sexual assault can occur without leaving physical marks. However, when medical evidence is inconsistent with the allegations, it raises serious doubts about the reliability of the prosecution's case. This judgment emphasizes the need for medical professionals to conduct thorough examinations and to provide clear, objective reports that can assist the court in determining the facts.

Another important implication of the judgment is its treatment of hostile witnesses. The victim in this case turned hostile during the trial and denied the allegations against the accused. Despite this, the trial court relied on the victim's earlier statement to convict the accused. The High Court found this approach to be problematic, as it violated established principles of evidence law. This aspect of the judgment has broader implications for how courts should deal with hostile witnesses, particularly in cases involving sexual offences.

In many sexual assault cases, victims turn hostile for various reasons, including family pressure, social stigma, threats from the accused or their associates, or a desire to move on from the traumatic experience. When a victim turns hostile, the prosecution faces significant challenges in proving the case. However, the law provides certain safeguards to deal with hostile witnesses. Under Section 145 of the Evidence Act, a witness may be cross-examined on previous statements to impeach their credit. Additionally, under Section 157, previous statements may be used to corroborate testimony. However, these provisions must be applied carefully, and courts must ensure that convictions are not based solely on statements that have been contradicted by the witness in court.

The Uttarakhand High Court's judgment also has implications for the application of the POCSO Act. The POCSO Act was enacted to provide stringent punishment for sexual offences against children and to establish special procedures for the trial of such cases. The Act creates certain presumptions in favor of the prosecution, such as the presumption of guilt under Section 29, which states that when sexual assault is proved and the question is whether the accused committed the offence, the court shall presume that the accused committed the offence. However, this presumption applies only when the basic fact of sexual assault has been proved. In this case, the High Court found that the prosecution had failed to prove even the basic fact of penetrative sexual assault, and therefore, the presumption under Section 29 could not be invoked.

This aspect of the judgment is important because it clarifies that the presumptions under the POCSO Act do not relieve the prosecution of its duty to prove the case beyond reasonable doubt. The foundational principle of criminal jurisprudence—that the accused is presumed innocent until proven guilty—remains applicable even in POCSO cases. The judgment serves as a reminder that while the POCSO Act provides for stringent punishment and special procedures, it does not authorize convictions based on inadequate or unreliable evidence.

The judgment also has practical implications for trial courts. The High Court's criticism of the trial court's judgment—characterizing it as "more than shocking"—indicates that trial courts must exercise greater care in evaluating evidence and ensuring that convictions are based on reliable, admissible evidence. Trial courts must critically examine the evidence presented by the prosecution and must not convict the accused merely because the allegations are serious or because of public pressure. The judgment serves as a reminder that trial courts have a duty to ensure that justice is done, and that this duty includes protecting the innocent from wrongful conviction.

From a broader perspective, the judgment highlights the challenges faced by the criminal justice system in handling cases involving sexual offences against children. These cases are often emotionally charged and involve vulnerable victims who may be traumatized by the experience. At the same time, the accused is entitled to a fair trial and to the presumption of innocence. Balancing these competing interests requires a criminal justice system that is professional, well-resourced, and committed to the principles of fairness and due process.

The judgment also raises questions about the adequacy of legal aid and representation for accused persons in criminal cases. In this case, the accused was represented by a competent advocate who was able to effectively challenge the prosecution's case and secure bail. However, many accused persons, particularly those from economically disadvantaged backgrounds, do not have access to quality legal representation. This can result in wrongful convictions based on inadequate evidence. The judgment underscores the importance of ensuring that all accused persons have access to competent legal representation, as guaranteed by Article 22(1) of the Constitution.

Finally, the judgment has implications for the role of appellate courts in the criminal justice system. The High Court's willingness to scrutinize the trial court's judgment and to grant bail despite the conviction demonstrates the important role that appellate courts play in preventing miscarriage of justice. Appellate courts serve as a check on trial courts and ensure that convictions are based on reliable evidence and sound legal reasoning. This judgment is an example of the appellate court performing this function effectively.

FAQs – Common Questions About Police Evidence and Criminal Trials

Q1: Is police evidence admissible in Indian courts?

Yes, police evidence is generally admissible in Indian courts, subject to certain limitations and safeguards. Police officers can testify as witnesses about facts they have personally observed, evidence they have collected, and the results of their investigation. Their testimony is evaluated like that of any other witness under the provisions of the Indian Evidence Act, 1872. However, there are important restrictions on the admissibility of certain types of police evidence. Under Section 25 of the Evidence Act, confessions made to police officers are not admissible as evidence against the accused. Similarly, Section 26 bars confessions made in police custody unless made in the immediate presence of a magistrate. These provisions reflect concerns about the potential for coercion and abuse of power during police custody. Additionally, statements made to police officers during investigation, as recorded under Section 161 of the Criminal Procedure Code, cannot be used as substantive evidence but can be used to contradict the witness under Section 162 of the CrPC. Courts have consistently held that while police testimony is admissible, it should be scrutinized carefully and should ideally be corroborated by independent evidence, especially in cases involving serious offences.

Q2: Can a person be convicted solely on the basis of police evidence without independent corroboration?

While it is legally possible for a person to be convicted solely on the basis of police evidence, courts have consistently held that such evidence should be scrutinized carefully and should ideally be corroborated by independent evidence. The Supreme Court has repeatedly emphasized that police officers are interested witnesses, as they are responsible for investigating the crime and securing a conviction. Therefore, their testimony should be treated with caution, particularly when it is the sole basis for conviction. In cases involving serious offences, courts generally look for independent corroboration of police evidence, such as forensic evidence, medical evidence, or testimony from independent witnesses. The Uttarakhand High Court's judgment in *Rampal v. State of Uttarakhand* illustrates this principle. The court found that the conviction was based primarily on police investigation without adequate independent corroboration, and that critical evidence such as the place of occurrence, forensic evidence linking the accused to the crime, and medical evidence supporting the allegations were absent. The court characterized the case as one of "no evidence at all" and held that the conviction was unsustainable. This judgment underscores the importance of independent corroboration in criminal cases and the need for courts to critically examine police evidence before convicting the accused.

Q3: What happens when a victim turns hostile in a criminal trial?

When a victim turns hostile in a criminal trial, it creates significant challenges for the prosecution. A hostile witness is one who, despite being called by the prosecution, gives evidence that is unfavorable to the prosecution's case or contradicts their earlier statements. In such situations, the prosecution can seek the court's permission to cross-examine the witness under Section 154 of the Evidence Act. During cross-examination, the prosecution can confront the witness with their previous statements to impeach their credit. However, the previous statements cannot generally be used as substantive evidence of the facts stated therein. Under Section 157 of the Evidence Act, previous statements may be used to corroborate the witness's testimony, but this applies only when the witness's testimony in court is consistent with the previous statement. In the *Rampal* case, the victim turned hostile and denied the allegations against the accused. The trial court relied on the victim's earlier statement to convict the accused, but the High Court found this approach problematic, noting that the earlier statement was not marked as an exhibit and was not made part of the record. The High Court emphasized that nothing incriminating against the accused had been elicited during cross-examination of the victim. This aspect of the judgment highlights the importance of following proper procedures when dealing with hostile witnesses and ensuring that convictions are not based solely on statements that have been contradicted in court.

Conclusion – Final Thoughts and Future Developments

The Uttarakhand High Court's judgment in *Rampal v. State of Uttarakhand* is a significant contribution to the jurisprudence on evidence in criminal cases, particularly in cases involving sexual offences against children. The judgment reaffirms fundamental principles of criminal law and evidence, including the presumption of innocence, the burden of proof on the prosecution, and the requirement that convictions be based on reliable, admissible evidence. It also highlights the importance of thorough police investigation, proper collection and analysis of forensic evidence, and careful judicial scrutiny of evidence.

The judgment serves as a reminder that the gravity of the offence cannot justify a departure from established principles of evidence and criminal procedure. While the POCSO Act provides for stringent punishment and special procedures for cases involving sexual offences against children, it does not authorize convictions based on inadequate or unreliable evidence. The foundational principle of criminal jurisprudence—that the accused is presumed innocent until proven guilty—remains applicable even in POCSO cases.

Looking ahead, this judgment is likely to have several implications for the criminal justice system in India. First, it may lead to greater scrutiny of police investigation and trial court judgments in sexual assault cases. Appellate courts may be more willing to examine the evidence critically and to overturn convictions that are based on insufficient or unreliable evidence. Second, the judgment may encourage investigating agencies to improve their investigative procedures, particularly in relation to the collection and analysis of forensic evidence. The emphasis on DNA testing and the need to establish the place of occurrence may lead to more thorough and professional investigations.

Third, the judgment may prompt discussions about the need for better training and resources for police officers, forensic experts, and medical professionals involved in investigating and prosecuting sexual assault cases. The deficiencies highlighted in this case—such as the failure to conduct DNA testing, the lack of evidence regarding the place of occurrence, and the reliance on inconclusive medical evidence—suggest that there is a need for capacity building and institutional reforms to ensure that the criminal justice system can effectively handle such cases.

Fourth, the judgment may have implications for the treatment of hostile witnesses in criminal trials. The High Court's criticism of the trial court's reliance on the victim's earlier statement, despite the victim turning hostile, may lead to greater caution in how courts deal with such situations. There may be a need for clearer guidelines on when and how previous statements can be used when a witness turns hostile, and on the weight to be given to such statements.

Finally, the judgment underscores the importance of access to justice and legal representation for accused persons. The fact that the accused in this case was able to secure bail and have the conviction suspended pending appeal demonstrates the value of competent legal representation. However, many accused persons, particularly those from economically disadvantaged backgrounds, do not have access to quality legal representation. Ensuring that all accused persons have access to competent legal aid is essential to preventing wrongful convictions and ensuring that the criminal justice system operates fairly.

In conclusion, the Uttarakhand High Court's judgment in *Rampal v. State of Uttarakhand* is an important reminder of the principles that should guide the administration of criminal justice in India. It emphasizes the need for thorough investigation, reliable evidence, and careful judicial scrutiny. It also highlights the challenges faced by the criminal justice system in handling cases involving sexual offences against children, and the need for reforms to ensure that justice is done in such cases. As the criminal justice system continues to evolve, judgments like this one will play an important role in shaping the law and ensuring that the rights of both victims and accused persons are protected.

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