Baddam Prashanth Reddy vs. State of Andhra Pradesh, 2025
The case reinforces the safeguard under Section 118 to prevent wrongful convictions based on untested child testimony.
Judgement Details
Court
Telangana High Court
Date of Decision
18 December 2025
Judges
Justice J. Sreenivas Rao
Citation
Acts / Provisions
Facts of the Case
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The accused, Baddam Prashanth Reddy, was convicted by the Special Sessions Judge under Section 377 IPC for allegedly committing sexual assault on a minor male student.
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The victim, a child, reported that the accused, his tuition teacher, forced himself on him and threatened him with poor grades if he disclosed the act.
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The victim confided in a friend, who informed the mother, and the father filed a police complaint.
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During the trial, the trial court convicted the accused relying primarily on the child’s testimony (minor PW.2) and the potency certificate (Ex.P3).
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The victim and his father refused medical examination, leading to absence of corroborative medical evidence.
Issues
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Whether the trial court erred in convicting the accused solely based on the child’s testimony without conducting a competency assessment under Section 118 of the Evidence Act?
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Whether the child’s testimony was reliable and untutored?
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Whether the absence of medical corroboration affected the validity of the conviction?
Judgement
- Section 118 mandates a preliminary competency assessment of a child witness to ensure the child can understand questions and provide coherent, rational answers.
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The trial court failed to conduct this assessment, making the conviction unsafe.
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Reliance solely on the minor’s testimony and potency certificate without corroboration is materially deficient.
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The court emphasized that a child’s testimony must be credible, voluntary, and untutored, and any suspicion of tutoring must be substantiated by evidence.
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The Supreme Court precedents (State of NCT of Delhi vs. Dharmender; State of Madhya Pradesh v. Balveer Singh; Pradeep vs. State of Haryana) reinforce that competency assessment is indispensable when conviction rests on uncorroborated child testimony.
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The Telangana High Court set aside the conviction.
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The accused, Baddam Prashanth Reddy, was acquitted.
Held
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Conviction based solely on uncorroborated child testimony without competency assessment is legally unsustainable.
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Mandatory compliance with Section 118 is necessary to ensure the child witness is competent.
Analysis
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The case reinforces the safeguard under Section 118 to prevent wrongful convictions based on untested child testimony.
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The judgment highlights the need for preliminary judicial inquiry into the child’s ability to testify, ensuring justice and fairness.
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It serves as a binding precedent for cases where the entire conviction is based on a minor’s statement without corroboration.