The Supreme Court of India recently quashed the conviction of an accused under rape and kidnapping charges after considering that he had married the victim and they had four children together. The Court exercised its inherent powers under Article 142 of the Indian Constitution, ensuring complete justice in this specific case.

Case Background

The case revolved around an FIR lodged in 1997 against three accused persons for crimes, including rape and kidnapping. The Trial Court, in 1999, convicted the appellant while acquitting the other two co-accused. In 2019, the High Court upheld the appellant’s conviction. The appellant then approached the Supreme Court, challenging the judgment.

In 2003, the appellant married the victim, and they now have four children. The Supreme Court acknowledged this and considered it a key factor in the case.

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During the hearing, the appellant argued that maintaining his conviction would lead to greater injustice, disrupting his family life. The complainant, who was now his wife, also supported his plea.

"Bearing in mind the fact that in this case, the appellant-accused has subsequently married the second respondent-prosecutrix and they have four children out of their wedlock, we find that the peculiar facts and circumstances of this case would persuade us to exercise our jurisdiction and powers under Article 142 of the Constitution of India by following earlier dicta of this case in the aforesaid orders."

On the contrary, the State opposed the appeal, arguing that at the time of the offence, the victim was a minor. The prosecution asserted that marriage could not erase the charges established against the accused.

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A bench comprising Justices B.V. Nagarathna and Satish Chandra Sharma deliberated on the facts and emphasized that Article 142 grants the Supreme Court special powers to ensure complete justice. However, the Court clarified that such powers should be used sparingly and only in exceptional circumstances.

The Court referred to previous judgments, including:

• K. Dhandapani vs. State by the Inspector of Police (2022 SCC Online SC 1056)
• Dasari Srikanth vs. State of Telangana (2024 SCC Online SC 936)

In both cases, the Supreme Court exercised its extraordinary powers under Article 142 to quash convictions when the accused had married the victim and started a family.

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"In the peculiar facts and circumstances of this case, we are of the considered view that the conviction and sentence of the appellant deserves to be set aside in view of the subsequent events that have been brought to the notice of this Court."

"The affirmation of the High Court judgment would have a disastrous consequence on the accused being sent to jail, which in turn could put his matrimonial relationship in danger."

Considering the unique facts of the case, the Supreme Court set aside the High Court’s decision and acquitted the appellant of all charges.

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"As a result, the impugned judgment dated 25.04.2019 by the High Court is quashed, and the appellant is acquitted of all charges."

This decision highlights the Court's discretionary powers under Article 142, reaffirming that legal proceedings must also consider the impact on social and familial structures while ensuring justice.