The Orissa High Court has upheld the conviction of a man sentenced to 20 years in prison for repeatedly sexually assaulting a minor, ruling that a later marriage between the victim and the accused cannot dilute criminal liability under the Protection of Children from Sexual Offences (POCSO) Act.
Justice Dr. Sanjeeb K. Panigrahi dismissed the appeal filed by Sanat Kumar Pradhan, affirming the trial court’s findings that the prosecution had proved the charges beyond reasonable doubt.
Read also:- Madras High Court Acquits Man in POCSO Case, Says Failure to Prove Victim’s Age Fatally Weakens Prosecution
Background of the Case
The case dates back to July 2016, when the victim-then about 17 years old—alleged that the accused entered her house while her parents were away and forcibly had sexual intercourse with her. According to the prosecution, he threatened her not to disclose the incident.
The victim later informed her mother. A meeting was reportedly held in the village, where the accused allegedly admitted the incident and agreed to marry the girl after she became a major.
Over the following years, the accused continued visiting the victim and maintaining physical relations with her. The two eventually married in May 2021 after the victim attained majority. However, their marital relationship lasted only about 10–15 days, after which the accused left and stopped contacting her.
The victim later alleged harassment by her in-laws and eventually filed an FIR in January 2024, nearly eight years after the first alleged incident.
Trial Court Decision
The trial court examined 16 witnesses, including the victim, her mother, doctors, and investigating officers.
After assessing the evidence, the court concluded that the accused had committed repeated sexual acts with the victim when she was still a minor. It relied primarily on the testimony of the victim and her mother, along with the school admission register to determine her age.
The accused was convicted under Section 6(1) of the POCSO Act and Section 376(2)(n) of the IPC for repeated rape and sentenced to 20 years’ rigorous imprisonment with a fine of ₹20,000.
The court also ordered compensation of ₹5 lakh to the victim through the District Legal Services Authority.
Meanwhile, the accused’s parents were acquitted of charges of cruelty and criminal intimidation due to lack of specific evidence.
Arguments Before the High Court
The defence challenged the conviction on several grounds. It argued that the FIR was filed after an unexplained delay of nearly eight years and that the prosecution relied mainly on the statements of the victim and her mother.
It was also argued that the victim eventually married the accused, which indicated that the relationship was consensual rather than forced.
The defence further questioned the determination of the victim’s age and pointed out alleged gaps in the investigation, including the non-examination of certain witnesses.
On the other hand, the State maintained that the victim’s testimony was clear and reliable and that in sexual offence cases a conviction can be based solely on the statement of the victim if it inspires confidence.
The prosecution also argued that the delay in filing the complaint was explained by the village settlement and the understanding that the accused would marry the victim after she attained majority.
Court’s Observations
After reviewing the evidence, the High Court noted that the testimony of the victim remained consistent and credible throughout the proceedings.
“The conviction can be sustained on the sole testimony of the prosecutrix if it inspires confidence,” the court observed, reiterating established legal principles in sexual offence cases.
The court also held that delay in filing the FIR is not automatically fatal in sexual assault cases, especially when social pressures or community intervention may discourage immediate reporting.
Addressing the argument regarding the subsequent marriage, the court made it clear that such developments cannot erase criminal liability if the offence occurred when the victim was a minor.
“Criminal liability attaches to the act at the time of its commission… a later marriage cannot retrospectively legitimise conduct that occurred when the victim was below eighteen,” the court noted.
Court Criticises Village Settlements
The court also expressed concern over the practice of resolving serious allegations through informal village meetings instead of reporting them to authorities.
It noted that offences against children must be reported to the police under the POCSO Act and cannot be settled through community discussions or promises of marriage.
According to the court, village leaders and local bodies have no authority to adjudicate criminal offences or suppress allegations involving minors.
Decision
After re-examining the evidence, the High Court found no illegality or perversity in the trial court’s judgment.
The court therefore dismissed the appeal and upheld the conviction and 20-year sentence imposed on the accused. It also directed district authorities and police to conduct awareness programmes so that local community leaders understand their legal duty to report offences against children.
Case Title: Sanat Kumar Pradhan v. State of Odisha
Case No.: CRLA No. 1145 of 2025
Decision Date: 13 February 2026
