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Wednesday, May 8

Supreme Court on evidence of Child witnesses: Shivasharanappa and others vs. State of Karnataka


Shivasharanappa and others vs. State of Karnataka, Criminal Appeal No. 1366 of 2007 & Jagadevappa and others vs. State of Karnataka, Criminal Appeal No. 508 of 2007, Decided on May 7, 2013

The Hon’ble Supreme Court held that:


“it is well settled in law that the court can rely upon the testimony of a child witness and it can form the basis of conviction if the same is credible, truthful and is corroborated by other evidence brought on record. Needless to say, the corroboration is not a must to record a conviction, but as a rule of prudence, the court thinks it desirable to see the corroboration from other reliable evidence placed on record. The principles that apply for placing reliance on the solitary statement of witness, namely, that the statement is true and correct and is of quality and cannot be discarded solely on the ground of lack of corroboration, applies to a child witness who is competent and whose version is reliable.” [Para 16]


The Court noted following case law in this respect:

Dattu Ramrao Sakhare and others v. State of Maharashtra (1997) 5 SCC 341, while dealing with the reliability of witness who was ten years old, this Court opined that a child witness, if found competent to depose to the facts and reliable, such evidence could form the basis of conviction. The evidence of a child witness and the credibility thereof would depend upon the circumstances of each case. The only precaution which the court should bear in mind while assessing the evidence of a child witness is that the witness must be a reliable one and his/her demeanour must be like any other competent witness and there is no likelihood of being tutored. Thereafter, the Court proceeded to lay down that there is no rule or practice that in every case the evidence of such a witness should be corroborated before a conviction can be allowed to stand but, as a rule of prudence, the court always finds it desirable to seek the corroboration to such evidence from other dependable evidence on record.

Panchhi and others v. State of U.P. (1998) 7 SCC 177, it has been held thus: -

“Courts have laid down that evidence of a child witness must find adequate corroboration before it is relied on. It is more a rule of practical wisdom than of law (vide Prakash v. State of M.P. (1992) 4 SCC 225 , Baby Kandayanathil v. State of Kerala  1993 Supp (3) SCC 667, Raja Ram Yadav v. State of Bihar (1996) 9 SCC 287 and Dattu Ramrao Sakhare v. State of Maharashtra (1997) 5 SCC 341.


State of U.P. v. Ashok Dixit and another  (2000) 3 SCC 70


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