VidhiSangh

Supreme Court of India · 27/04/2021

PATAN JAMAL VALI versus THE STATE OF ANDHRA PRADESH

[2021] 3 S.C.R. 470 · 2021 INSC 272

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Summary

The Court set aside the conviction under the pre-2016 SC/ST Act because evidence did not establish the required caste-based causal link, while affirming the rape conviction and life sentence. Knowledge of caste alone did not satisfy the provision applicable to the 2011 offence. It affirmed equal evidentiary weight for credible testimony by survivors with disabilities, explained intersectional disadvantage and proposed systemic measures for accessible criminal justice.

Issues

  1. Whether the evidence met the pre-amendment requirement that the offence be committed on the ground of caste.
  2. Whether setting aside the SC/ST Act conviction required reduction of the independently imposed rape sentence.
  3. How disability and intersecting disadvantage should inform evidence assessment and access to justice.

Provisions considered

Held

Result

Appeal allowed to the extent of setting aside the Section 3(2)(v) conviction and sentence. Section 376(1) conviction, life imprisonment, Rs. 1,000 fine and six months’ default imprisonment affirmed; pending applications disposed of.

Judgment PDF: Supreme Court of India, [2021] 3 S.C.R. 470.