Supreme Court Modifies Life Sentence in Child Sexual Assault Case: Key Legal Analysis

The Supreme Court of India has ruled on a highly sensitive and serious case involving child sexual assault. The accused, Gyanendra Singh @ Raja Singh, was convicted for the rape of his own 9-year-old daughter under Sections 376(2)(f) and 376(2)(i) of the Indian Penal Code (IPC) and Sections 3/4 of the Protection of Children from Sexual Offences (POCSO) Act, 2012. While upholding the conviction, the Supreme Court modified the punishment imposed by the High Court, reducing the sentence from ‘for the remainder of his natural life’ to life imprisonment with a fixed term.

Background of the Case

The case originated from FIR No. 236 of 2015, registered at Police Station Chandpur, District Fatehpur, Uttar Pradesh, on October 28, 2015. The complainant, Rajani, the wife of the accused, alleged that her husband had sexually assaulted their minor daughter. According to the FIR:

The complainant had left her 9-year-old daughter and 4-year-old son at home while she visited her parental house with her 2-year-old child.
On October 22, 2015, the accused took the minor girl to the rooftop at night and sexually assaulted her.
The child was detained on the roof overnight and threatened into silence.
The next morning, she narrated the incident to her grandfather, Ram Naresh Singh, who informed the complainant.
Upon learning of the crime, the complainant filed a police report.

Investigation and Medical Evidence

The investigation was led by Rajesh Kumar Singh (PW-7), the Investigating Officer. The victim was medically examined by Dr. Manisha Shukla (PW-4), who noted:

Absence of external injuries.
Redness over the labia minora.
Intact hymen, but vaginal swabs collected for forensic testing.

The victim provided a statement under Section 164 of the Criminal Procedure Code (CrPC), detailing the assault and threats from the accused.

Trial Court Conviction and Sentencing

The Additional Sessions Judge, Court No.2, Fatehpur, convicted the accused under:

Sections 376(2)(f) and 376(2)(i) of IPC (rape by a person in a position of trust).
Sections 3/4 of the POCSO Act (penetrative sexual assault on a minor).

The accused was sentenced to life imprisonment and fined Rs. 25,000. In default, an additional two-month imprisonment was imposed.

High Court Decision

The accused filed Jail Appeal No. 6590 of 2016 before the Allahabad High Court. On August 2, 2019, the High Court:

Dismissed the appeal, affirming the conviction.
Enhanced the sentence, directing that the life imprisonment term would extend for the remainder of the accused’s natural life.
Held that no separate sentence was required under the POCSO Act.

The enhancement of the sentence led to the present appeal before the Supreme Court.

Supreme Court’s Review of the Sentence

The Supreme Court issued notice on the limited question of sentencing. The accused’s counsel, R. Balasubramanian, argued:

That conviction should be under the POCSO Act alone, as it is a special law that overrides IPC provisions.
That the High Court had wrongly enhanced the sentence in an appeal against conviction.
That the modification of life imprisonment to ‘for the remainder of natural life’ was excessive.

The State’s counsel countered:

The accused had committed a heinous crime against his own child, justifying the strictest punishment.
The offense warranted a deterrent sentence to protect children from sexual abuse.
The High Court correctly ensured that the accused would never re-enter society.

Supreme Court’s Observations and Final Ruling

The Supreme Court ruled:

Conviction under IPC and POCSO Act was justified: Section 42 of the POCSO Act states that when an offense is punishable under both laws, the one prescribing the greater punishment shall prevail.
Sentence enhancement by the High Court was improper: The Court ruled that the High Court should not have increased the punishment beyond what was imposed by the Trial Court.
Modified sentence: The accused will serve life imprisonment as awarded by the Trial Court, but not for the remainder of his natural life.
Victim compensation: The Court directed that Rs. 5,00,000 be paid to the victim as compensation.

“We direct that the ends of justice would be served by restoring the judgment of the Trial Court and directing that the sentence of life imprisonment awarded to the accused shall stand revived.”

Key Takeaways from the Judgment

This ruling reaffirms the judiciary’s commitment to child protection.
The Supreme Court clarified that special laws like POCSO do not override IPC provisions when IPC prescribes a stricter punishment.
The judgment highlights that life imprisonment does not automatically mean imprisonment for natural life unless explicitly stated.
Victim compensation was prioritized to ensure financial restitution.

Conclusion

This judgment sets an important precedent in sentencing for child sexual abuse cases. It balances the need for severe punishment with fairness in sentencing. While the Supreme Court upheld the conviction, it also ensured that the punishment remained within the legal framework, reaffirming that those who commit crimes against children will face the full force of the law.

Petitioner Name: Gyanendra Singh @ Raja Singh.
Respondent Name: State of Uttar Pradesh.
Judgment By: Justice Vikram Nath, Justice Sandeep Mehta.
Place Of Incident: Fatehpur, Uttar Pradesh.
Judgment Date: 07-03-2025.

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