The Supreme Court upheld the conviction of the appellant under Sections 342 and 376 IPC, rejecting arguments about discrepancies in prosecution evidence and delay in FIR registration. However, the Court accepted the appellant’s juvenility claim under the Juvenile Justice Act, 2000, based on school records confirming his age as 16 years at the time of the offense. The sentence was set aside, and the case was referred to the Juvenile Justice Board for appropriate orders, affirming that juvenility can be raised at any stage, even post-conviction, as per precedents like Dharambir v. State (NCT of Delhi). The Court emphasized that credible prosecutrix testimony, corroborated by medical evidence, suffices for conviction in rape cases.
Facts Of The Case:
The case involves an appeal against the conviction and sentencing of the appellant for offenses under Sections 342 (wrongful confinement) and 376 (rape) of the Indian Penal Code. The incident occurred on 17 November 1988, when the appellant allegedly raped an 11-year-old girl in her Bada (courtyard) in Rajasthan. The victim reported the incident to her mother, who lodged an FIR the next morning, explaining the delay due to the police station being 26 km away and the short daylight hours in November. The appellant was convicted by the Additional Sessions Judge, Kishangarh, in 1993, and the conviction was upheld by the High Court in 2024.Before the Supreme Court, the appellant challenged the conviction, citing discrepancies in witness statements, including the victim’s brother turning hostile and claiming the case was fabricated due to a property dispute. The defense also highlighted the absence of fresh injuries in the medical report. However, the Court upheld the conviction, relying on the victim’s credible testimony and medical evidence.A key argument raised for the first time in the Supreme Court was the appellant’s claim of juvenility at the time of the offense. School records confirmed his date of birth as 14 September 1972, making him 16 years old during the incident. The Court accepted this plea, set aside the sentence, and referred the matter to the Juvenile Justice Board for appropriate action under the Juvenile Justice Act, 2000.
Procedural History:
The case began with the trial court’s conviction of the appellant on 2 February 1993, sentencing him to six months’ imprisonment under Section 342 (wrongful confinement) and five years’ rigorous imprisonment under Section 376 (rape) of the IPC, along with fines. The conviction was based on the testimony of the prosecutrix (victim), medical evidence, and witness statements, despite some witnesses turning hostile. The appellant challenged the conviction before the Rajasthan High Court, which upheld the trial court’s decision on 12 July 2024, affirming the findings on guilt and sentencing.Subsequently, the appellant filed a criminal appeal before the Supreme Court (Crl. A. No. 2695 of 2025), raising new grounds, including discrepancies in prosecution evidence and, for the first time, a claim of juvenility. The Supreme Court, in an interim order dated 20 January 2025, directed an inquiry into the appellant’s age by the Additional Sessions Judge, Kishangarh, under the Juvenile Justice Act, 2000. The inquiry confirmed the appellant was 16 years old at the time of the offense (born on 14 September 1972) In its final judgment on 23 July 2025, the Supreme Court upheld the conviction but set aside the sentence, ruling that the appellant was entitled to benefits under juvenile law. The case was referred to the Juvenile Justice Board for further proceedings under Sections 15 and 16 of the Juvenile Justice Act, 2000, and the appeal was disposed of accordingly.
READ ALSO :Supreme Court Slams Fraudulent Litigation, Nullifies Compensation Order in Land Dispute
Court Observation:
The Supreme Court made several key observations in its judgment. Firstly, it rejected the appellant’s challenge to the conviction, holding that the testimony of the prosecutrix was credible and consistent, supported by medical evidence and witness statements. The Court emphasized that corroboration is not mandatory in rape cases if the victim’s account inspires confidence, relying on precedents like Mohd. Imran Khan v. State (NCT of Delhi) and Ganesan v. State.Regarding the delay in FIR registration, the Court accepted the prosecution’s explanation that the police station was 26 km away and the victim’s family could only approach authorities the next morning. It held that the delay did not weaken the prosecution’s case, as it was sufficiently explained.On the juvenility claim, the Court conducted a detailed inquiry and confirmed the appellant was 16 years old at the time of the offense, based on school admission records showing his date of birth as 14 September 1972. Relying on precedents like Dharambir v. State (NCT of Delhi) and Hari Ram v. State of Rajasthan, the Court ruled that juvenility can be raised at any stage, even after conviction, and the benefits of the Juvenile Justice Act, 2000, must apply retrospectively Consequently, while upholding the conviction, the Court set aside the sentence and directed the case to be referred to the Juvenile Justice Board for appropriate orders under Sections 15 and 16 of the Juvenile Justice Act, 2000, affirming that the appellant could not be subjected to regular imprisonment given his juvenile status during the offense.
Final Decision & Judgement:
The Supreme Court, in its final judgment dated 23 July 2025, upheld the appellant’s conviction under Sections 342 and 376 of the IPC, affirming the findings of the trial court and the High Court that the prosecution had proved the case beyond reasonable doubt. The Court emphasized the reliability of the prosecutrix’s testimony, corroborated by medical evidence, and dismissed arguments about delayed FIR registration and witness discrepancies as inconsequential. However, the Court accepted the appellant’s juvenility claim, holding that he was 16 years old at the time of the offense, as established by school records. Relying on precedents like Dharambir v. State (NCT of Delhi) and Hari Ram v. State of Rajasthan, the Court ruled that the Juvenile Justice Act, 2000, applied retrospectively, entitling the appellant to its protective provisions. Consequently, while maintaining the conviction, the Court set aside the imposed sentence of imprisonment and fines, directing the case to be referred to the Juvenile Justice Board for appropriate orders under Sections 15 and 16 of the 2000 Act. The appeal was disposed of with these directions, and any pending applications were also closed. The judgment underscored the primacy of juvenile justice protections, even in long-pending cases, ensuring compliance with legislative intent and constitutional safeguards for minors.
Case Details:
Case Title: Sua v. State of Rajasthan Citation:2025 INSC 887 Criminal Appeal No.:Criminal Appeal No. 2695 of 2025 Date of Judgment:23 July 2025 Judges/Justice Name: Justice B.R. Gavai & Justice Augustine George Masih
Download The Judgement Here