Court caseAIR 1979 SC 185

Mathura, a young tribal girl, was called to a police station at night and, according to the prosecution, raped by two policemen inside the station. The Sessions Court acquitted them, finding consent; the High Court convicted, distinguishing passive submission from consent.

The Supreme Court restored the acquittal. It held that there were no injuries and no evidence of resistance, that the girl had not raised an alarm, and that fear of the police was not established, so the intercourse could not be said to be without consent. The judgment was widely criticised for equating submission with consent.