In a recent ruling dated July 25, 2025, the Supreme Court of India partially allowed an appeal in the case Satauram Mandavi v. State of Chhattisgarh & Anr. by modifying the sentence awarded under the Protection of Children from Sexual Offences (POCSO) Act. The Court held that retrospective application of enhanced punishment, introduced in the 2019 amendment, violates Article 20(1) of the Indian Constitution.
The appellant, Satauram Mandavi, was convicted by the Trial Court under Section 376AB of the IPC and Section 6 of the POCSO Act for raping a five-year-old minor girl. He was sentenced to imprisonment for life till the remainder of his natural life, along with a fine of ₹10,000. This sentence was affirmed by the High Court of Chhattisgarh on September 5, 2023.
However, the appellant challenged the sentence before the Supreme Court, limiting the challenge to the question of whether the amended provisions of Section 6 of POCSO, which came into effect on August 16, 2019, could be applied to an offence committed on May 20, 2019.
“The Constitutional bar against retrospective imposition of a harsher penalty under Article 20(1) is clear and absolute,”
– Supreme Court
Before the amendment, Section 6 of POCSO prescribed a sentence ranging from ten years to life imprisonment. After the amendment, the provision was made more stringent. It stated:
"Whoever commits aggravated penetrative sexual assault shall be punished with rigorous imprisonment for a term which shall not be less than twenty years, but which may extend to imprisonment for life, which shall mean imprisonment for the remainder of natural life of that person and shall also be liable to fine, or with death."
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The apex court acknowledged that although the conviction itself was valid, the sentence based on the amended provision was not legally sustainable since the amendment had not come into effect at the time of the offence.
The court invoked Article 20(1) of the Constitution, which guarantees:
"No person shall be convicted of any offence except for violation of a law in force at the time of the commission of the act charged as an offence, nor be subjected to a penalty greater than that which might have been inflicted under the law in force at the time of the commission of the offence."
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Hence, the Supreme Court concluded that the Trial Court's sentence violated Article 20(1) by applying the amended punishment retroactively.
“The sentence of ‘imprisonment for life, meaning remainder of natural life,’ as per the amended provision, did not exist in the statutory framework on 20.05.2019,”
– Supreme Court
In light of this, the Court upheld the appellant’s conviction but modified the sentence to rigorous life imprisonment as per the unamended Section 6. The fine of ₹10,000 remained unchanged. The appeal was partly allowed accordingly.
Case Details: Satauram Mandavi vs. State of Chhattisgarh & others | SLP (CRL) No. 13834 of 2024