VidhiSangh

Supreme Court of India · 25/07/2025

SATAURAM MANDAVI versus THE STATE OF CHHATTISGARH & ANR.

[2025] 7 S.C.R. 1538 · 2025 INSC 892

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Summary

Appeal by special leave, confined to sentence, against conviction under Section 376AB IPC and Section 6 of the POCSO Act with a sentence of imprisonment for the remainder of natural life. The offence was committed on 20.05.2019, before the POCSO (Amendment) Act, 2019 came into force on 16.08.2019, so the enhanced punishment introduced by the amendment could not be applied without violating Article 20(1). Conviction upheld; sentence modified to rigorous imprisonment for life as understood under the unamended Section 6.

Issues

  1. Whether a sentence of imprisonment for the remainder of natural life under Section 6 of the POCSO Act, as amended in 2019, could be imposed for an offence committed on 20.05.2019, before the amendment came into force on 16.08.2019.

Provisions considered

Held

Result

Appeal partly allowed. Conviction under Section 6 of the POCSO Act upheld; sentence of imprisonment for the remainder of natural life set aside and substituted with rigorous imprisonment for life as understood under the unamended Section 6; fine of Rs. 10,000 maintained; pending applications disposed of.

Judgment PDF: Supreme Court of India, [2025] 7 S.C.R. 1538.