In a significant ruling on 10 September 2025, the Supreme Court of India modified the conviction of Laxman Jangde, who had earlier been sentenced to twenty years in prison for allegedly raping a minor. The bench of Justices Ahsanuddin Amanullah and Joymalya Bagchi concluded that the evidence did not support charges of rape or penetrative sexual assault.
Background
Jangde was convicted by a trial court in July 2022 under Section 376AB of the Indian Penal Code (IPC) and Section 6 of the Protection of Children from Sexual Offences (POCSO) Act. The Chhattisgarh High Court upheld the conviction in January 2025, leading to his appeal. The prosecution claimed that Jangde, a neighbour of the victim, had sexually assaulted a girl under twelve years of age. He had already spent over five and a half years in jail when the matter reached the apex court.
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Court’s Observations
The Supreme Court closely examined the FIR, the child’s statement recorded before a magistrate, and her deposition during the trial. “The so-called act of the appellant will come under the purview of Section 354 of the IPC and Section 9(m) of the POCSO Act,” the bench observed, noting that no medical or witness evidence proved penetration.
The judges pointed out that touching the victim’s private parts, as alleged, did not meet the legal definition of rape under Section 375 of the IPC or penetrative assault under Section 3(c) of the POCSO Act.
Justice Amanullah remarked, “The presumption by the Trial Court as upheld by the High Court that there was penetrative sexual assault, cannot be sustained.”
Decision
Allowing the appeal in part, the Supreme Court set aside the convictions for rape and penetrative assault. Jangde was instead found guilty of outraging a woman’s modesty under Section 354 of the IPC and aggravated sexual assault on a child under Section 10 of the POCSO Act. His sentence was reduced to five years under the IPC and seven years under the POCSO Act, to run concurrently. The fine of ₹50,000 remains, to be paid to the victim as compensation within two months.
Case Title: Laxman Jangde vs. State of Chhattisgarh
Date of Judgment: 10 September 2025