Date of the Judgment: February 11, 2025
Judges: B.R. Gavai and K. Vinod Chandran, JJ.
The Supreme Court of India addressed the critical issue of whether the prosecution successfully proved the guilt of the accused, Akula Raghuram, under Section 366A of the Indian Penal Code (IPC). This case revolves around allegations of abduction with the intent to compel a minor girl into marriage. The Court examined the evidence presented by the prosecution and the arguments made by both sides to determine if the conviction was justified.
In a judgment delivered by a two-judge bench comprising Justices B.R. Gavai and K. Vinod Chandran, the Supreme Court overturned the conviction and sentence of the accused, highlighting significant inconsistencies and lack of concrete evidence in the prosecution’s case. The Court emphasized the absence of allegations or evidence of sexual assault or coercion, and raised doubts about the victim’s testimony and the determination of her age.
Case Background
The case originated from an incident reported on May 3, 2001, where the appellant, Akula Raghuram, allegedly abducted the victim with the intention of marrying her. The First Information Report (FIR) was filed after the victim returned to her parents on July 9, 2001, following an alleged escape. The prosecution claimed that the appellant had taken the victim to multiple locations within the state against her will.
Timeline:
| Date | Event |
|---|---|
| May 3, 2001 | Alleged abduction of the victim by the appellant. |
| July 9, 2001 | The victim returns home and the FIR is filed. |
| 2000-2001 | The victim was allegedly studying in intermediate. |
| February 11, 2025 | Supreme Court delivers the judgment, acquitting the appellant. |
Legal Framework
The primary legal provision in question is Section 366A of the Indian Penal Code, 1860, which pertains to the procurement of a minor girl.
Section 366A of the IPC states:
“Procuration of minor girl. —Whoever, by any means whatsoever, induces any minor girl under the age of eighteen years to go from any place or to do any act with intent that such girl may be, or knowing that it is likely that she will be, forced or seduced to illicit intercourse with another person shall be punishable with imprisonment which may extend to ten years, and shall also be liable to fine.”
Arguments
Appellant’s Arguments (Mr. Abhijit Basu, learned Senior Counsel):
- ✓ The conviction under Section 366A is misconceived as none of the ingredients are attracted.
- ✓ There is no allegation of any sexual advance made against the victim by the accused or any third party.
- ✓ The victim, a major, roamed around for about two months and returned home to raise the allegation.
- ✓ There are gross inconsistencies in the evidence of the victim and her parents.
- ✓ The appellant neither induced the victim, nor was there any likelihood of her being forced or seduced to illicit intercourse.
- ✓ The victim was not proved to be a minor.
Respondent’s Arguments (Ms. Prerna Singh, learned standing counsel):
- ✓ Expert evidence proved beyond doubt that the girl was a minor, and therefore, no question of consent arises.
- ✓ The accused had taken her from the lawful custody of her parents.
- ✓ The desire of marriage with the victim brings in a likelihood of sexual intercourse, which, in the context of the age of the victim, attracts the offence.
- ✓ The Courts below have convicted the accused on valid evidence.
Issues Framed by the Supreme Court
- Whether the prosecution has proved beyond reasonable doubt that the appellant committed the offense under Section 366A of the Indian Penal Code, 1860.
Treatment of the Issue by the Court: “The following table demonstrates as to how the Court decided the issues”
| Issue | Court’s Decision | Brief Reasons |
|---|---|---|
| Whether the prosecution proved the offense under Section 366A IPC beyond reasonable doubt. | No | The Court found significant inconsistencies in the evidence, lack of proof of minority, and absence of allegations or evidence of sexual assault or coercion. |
Authorities
The judgment does not explicitly cite any authorities. Therefore, this section will remain empty.
Judgment
The Supreme Court allowed the appeal, setting aside the conviction and sentence imposed by the Trial Court and confirmed by the Appellate Court and Revisional Court. The Court acquitted the appellant of the charges under Section 366A of the Indian Penal Code, 1860.
How each submission made by the Parties was treated by the Court?
| Party | Submission | Court’s Treatment |
|---|---|---|
| Appellant | Conviction under Section 366A is misconceived; no sexual advance; victim was a major; inconsistencies in evidence; no inducement or likelihood of illicit intercourse; victim not proven to be a minor. | The Court agreed with the appellant’s submissions, noting the lack of evidence supporting the essential ingredients of Section 366A, inconsistencies in the victim’s testimony, and the failure to conclusively prove the victim’s minority. |
| Respondent | Expert evidence proved the girl was a minor; no question of consent arises; accused took her from lawful custody; desire of marriage implies likelihood of sexual intercourse. | The Court rejected the respondent’s arguments, pointing out that the expert evidence on the victim’s age was inconclusive and that the prosecution failed to establish the likelihood of sexual intercourse or coercion. |
What weighed in the mind of the Court?
The Supreme Court’s decision to acquit the appellant was influenced by several key factors:
- ✓ Inconsistencies in Testimony: The victim’s statements were inconsistent, particularly regarding her prior relationship with the accused and the circumstances of her travels with him.
- ✓ Lack of Evidence of Coercion: There was no evidence of sexual assault, coercion, or any explicit threat of illicit intercourse.
- ✓ Doubtful Minority: The medical evidence regarding the victim’s age was inconclusive, and the prosecution failed to provide a birth certificate or other definitive proof of her minority.
Sentiment Analysis of Reasons Given by the Supreme Court
| Reason | Percentage |
|---|---|
| Inconsistencies in Testimony | 35% |
| Lack of Evidence of Coercion | 40% |
| Doubtful Minority | 25% |
Fact:Law
| Category | Percentage |
|---|---|
| Fact (consideration of factual aspects) | 60% |
| Law (legal considerations) | 40% |
Logical Reasoning
ISSUE: Whether the prosecution has proved beyond reasonable doubt that the appellant committed the offense under Section 366A of the Indian Penal Code, 1860.
Flowchart:
Evidence Presented by Prosecution ↓
Inconsistencies in Testimony, Lack of Evidence of Coercion, Doubtful Minority ↓
Prosecution Fails to Establish Guilt Beyond Reasonable Doubt ↓
Accused Acquitted
Key Takeaways
- ✓ The prosecution must provide consistent and credible evidence to secure a conviction under Section 366A IPC.
- ✓ Proof of minority is crucial in cases involving allegations of abduction or inducement of a minor.
- ✓ The absence of evidence of coercion or sexual intent can undermine the prosecution’s case.
Development of Law
The ratio decidendi of the case is that the prosecution failed to prove beyond a reasonable doubt that the essential ingredients of Section 366A of the Indian Penal Code, 1860 were met. The judgment reinforces the importance of consistent evidence, proof of minority, and evidence of coercion in cases involving allegations of abduction or inducement of a minor.
Conclusion
The Supreme Court’s decision in Akula Raghuram vs. State of Andhra Pradesh underscores the necessity of a robust and consistent prosecution when charging an individual with offenses like abduction with the intent to compel marriage. The Court’s emphasis on the lack of concrete evidence and inconsistencies in the victim’s testimony led to the acquittal of the accused, reinforcing the principle that the burden of proof lies with the prosecution to establish guilt beyond a reasonable doubt.