A) ABSTRACT / HEADNOTE

The judgment examines the legal permissibility of reversing an acquittal in an appeal under Section 378 of the Code of Criminal Procedure, 1973, in a prosecution concerning rape of a mentally retarded woman. The prosecutrix, whose IQ was assessed at 62, was found medically incapable of understanding the nature and consequences of sexual acts. The trial court had acquitted the accused primarily on grounds of delay in lodging the FIR and an erroneous appreciation of the prosecutrix’s mental capacity. The High Court reversed the acquittal after a complete re-appreciation of evidence, particularly medical and psychiatric testimony, and convicted the accused under Sections 376 and 506 of the Indian Penal Code, 1860.

The Supreme Court affirmed the High Court’s decision, holding that the trial court’s approach was perverse and contrary to settled principles governing sexual offences involving persons of unsound mind. The Court clarified the scope of appellate powers in acquittal appeals, reiterating that where material evidence is ignored and conclusions are illogical, reversal is justified.

The judgment significantly interprets clause fifthly of Section 375 IPC, emphasizing that consent obtained from a person incapable of understanding due to mental retardation is legally invalid. The Court underscored the obligation of courts to adopt a victim-centric approach in cases involving vulnerable persons and condemned exploitation of mental disability. The ruling reinforces judicial sensitivity towards sexual offences against persons with intellectual disabilities and strengthens the jurisprudence on appellate scrutiny of acquittals.

Keywords: Mental Retardation, Consent, Rape, Appeal against Acquittal, Section 375 IPC, Section 378 CrPC

B) CASE DETAILS

C) INTRODUCTION AND BACKGROUND OF JUDGEMENT

The judgment arose from an appeal challenging the High Court’s reversal of an acquittal in a rape prosecution involving a mentally retarded prosecutrix. The trial court had acquitted the accused by emphasizing procedural delay and by discounting psychiatric evidence relating to the victim’s intellectual functioning. This approach raised critical concerns about judicial treatment of vulnerable victims and the evidentiary value of expert medical testimony.

The High Court, exercising appellate jurisdiction under Section 378 CrPC, reassessed the entire record and concluded that the trial court had ignored vital evidence, particularly psychiatric assessments confirming mild mental retardation. The conviction was restored based on medical findings, DNA evidence establishing paternity, and the absence of any plea of consent by the accused.

Before the Supreme Court, the appellant contended that the High Court exceeded its jurisdiction by interfering with a plausible acquittal. The appeal thus squarely presented issues relating to the scope of appellate review, the legal meaning of consent, and the treatment of sexual offences against intellectually disabled persons.

The Court used this opportunity to consolidate precedents on appellate interference, clarify evidentiary standards in rape cases, and emphasize constitutional and human rights obligations toward persons with mental disabilities. The judgment forms part of a growing jurisprudence prioritizing substantive justice over procedural technicalities in sexual offence trials .

D) FACTS OF THE CASE

The prosecutrix, aged about 19 years, belonged to a rural background and used to graze cattle in nearby forests. The accused frequently accompanied her to these locations. It was alleged that he had forcible sexual intercourse with her on multiple occasions and threatened her with dire consequences if she disclosed the acts.

Due to her mental weakness and fear, the prosecutrix did not immediately disclose the incident. The pregnancy came to light only when it had advanced to approximately 31 weeks. Her father lodged an FIR upon being informed of her condition. Medical examination confirmed pregnancy, and subsequent psychiatric evaluations conducted at IGMC Shimla and PGI Chandigarh assessed her IQ at 62, categorizing her as suffering from mild mental retardation.

The prosecutrix delivered a female child, and DNA analysis conclusively established the accused as the biological father. The prosecution examined 23 witnesses, including medical experts and investigating officers.

Despite this evidence, the trial court acquitted the accused, reasoning that delay in FIR and the prosecutrix’s ability to perform household tasks negated the claim of mental incapacity. The High Court reversed this finding, holding the trial court’s conclusions to be manifestly erroneous.

The Supreme Court was called upon to assess whether this reversal was legally sustainable and whether the evidence satisfied the ingredients of rape under Section 375 IPC .

E) LEGAL ISSUES RAISED

i. Whether the High Court was justified in reversing the order of acquittal in an appeal under Section 378 CrPC?
ii. Whether a woman with mild mental retardation can legally consent to sexual intercourse under Section 375 IPC?
iii. Whether delay in lodging the FIR was fatal to the prosecution case?
iv. Whether medical and psychiatric evidence was wrongly discarded by the trial court?

F) PETITIONER / APPELLANT’S ARGUMENTS

The counsels for the appellant submitted that the trial court’s acquittal represented a plausible view and could not be interfered with merely because another view was possible. Emphasis was placed on the delay of several months in filing the FIR, arguing that it cast serious doubt on the prosecution’s veracity.

It was contended that contradictions between psychiatric witnesses regarding the language known by the prosecutrix undermined the credibility of mental assessment. Reliance was placed on Krishna v. State of Karnataka (2014) 15 SCC 596 to argue that appellate interference should be minimal.

The appellant further argued that the prosecutrix was capable of understanding her welfare and had informed family members of pregnancy, suggesting cognitive awareness. A plea for reduction of sentence was also advanced on humanitarian grounds .

G) RESPONDENT’S ARGUMENTS

The counsels for the State argued that the High Court acted well within its jurisdiction as the trial court had ignored crucial medical evidence. It was submitted that IQ testing is language-independent and minor discrepancies could not outweigh expert conclusions.

The State highlighted that the accused never pleaded consent and adopted a false defence of total denial under Section 313 CrPC, despite DNA evidence. Delay in FIR was justified due to the prosecutrix’s mental condition. The minimum statutory sentence was urged to be upheld .

H) JUDGEMENT

The Supreme Court dismissed the appeal and affirmed the conviction. The Court held that the High Court correctly identified the perversity in the trial court’s reasoning. It reiterated that appellate courts possess full power to re-appreciate evidence in acquittal appeals, particularly where material evidence is ignored.

The Court placed significant reliance on psychiatric testimony establishing the prosecutrix’s IQ of 62. It clarified that functional abilities such as household work do not negate mental retardation. Consent from a person incapable of understanding consequences is legally void under clause fifthly of Section 375 IPC.

The Court condemned the accused’s exploitation of the victim’s vulnerability and underscored the duty of courts to protect persons with mental disabilities. The minimum sentence imposed was found appropriate, and no mitigating factors warranted interference .

a) RATIO DECIDENDI

Consent obtained from a woman suffering from mild mental retardation who is incapable of understanding the nature and consequences of sexual intercourse is no consent in law, and sexual intercourse in such circumstances constitutes rape under Section 375 IPC.

An appellate court is justified in reversing an acquittal where the trial court ignores material medical evidence and arrives at conclusions that are illogical and unsustainable in law .

b) OBITER DICTA

Persons suffering from mental disorders deserve special care, love, and protection. Courts must adopt a sensitive and victim-centric approach while dealing with offences against such persons and ensure that legal processes do not become instruments of further victimization .

c) GUIDELINES

i. Medical evidence on mental capacity must be given primacy in sexual offence cases.
ii. Delay in FIR must be contextualized where victims suffer from mental disability.
iii. Appellate courts must intervene where acquittals are based on perverse reasoning.
iv. False defences under Section 313 CrPC can be used to draw adverse inference.

I) CONCLUSION & COMMENTS

The judgment is a strong reaffirmation of substantive criminal justice and judicial sensitivity toward vulnerable victims. It bridges doctrinal clarity on consent with humane interpretation of evidence. By upholding the High Court’s reversal, the Supreme Court sent a clear message that mental disability cannot be exploited under the guise of consent.

The ruling strengthens jurisprudence on appellate review and aligns Indian criminal law with international human rights standards protecting persons with disabilities. It serves as a vital precedent for law students, practitioners, and courts dealing with sexual offences involving intellectually disabled victims .

J) REFERENCES

a) Important Cases Referred

• Babu v. State of Kerala, [2010] 9 SCR 1039

• Kuldeep Singh v. Commissioner of Police, [1998] 3 Suppl. SCR 594

• Vijay Mohan Singh v. State of Karnataka, [2019] 6 SCR 994

• Krishna v. State of Karnataka, (2014) 15 SCC 596

b) Important Statutes Referred

• Indian Penal Code, 1860

• Code of Criminal Procedure, 1973