Arjun v. State, 2025
The Court emphasized due process and evidentiary standards, particularly when the only age proof (birth certificate and school record) is shown to be fabricated.
Judgement Details
Court
Delhi High Court
Date of Decision
19 September 2025
Judges
Justice Manoj Kumar Ohri
Citation
Acts / Provisions
Section 13(1)(ia), Hindu Marriage Act, 1955
Section 25, Hindu Marriage Act, 1955
Facts of the Case
-
The trial court convicted Arjun for rape of a minor, sentencing him to three years of rigorous imprisonment.
-
The prosecution alleged that the victim was a minor (born on 16.10.1995) at the time of the incident, rendering her consent immaterial under the law.
-
The main evidence regarding the victim’s minority was a birth certificate and school admission record, both submitted by her mother.
-
On appeal, the defense argued that the birth certificate was forged, and no ossification test or independent proof of age was conducted.
Issues
-
Whether the prosecution proved beyond reasonable doubt that the victim was a minor at the time of the incident?
-
Whether conviction under rape charges could be sustained based on a forged birth certificate?
-
Whether the consensual nature of the relationship alters the legal implications if minority is not proved?
Held
-
The conviction was set aside.
-
The High Court ruled that the trial court erred in convicting the appellant despite recording that the key document (birth certificate) was forged.
-
Since minority was not proved, consent becomes relevant, and the prosecution’s case collapsed.
Analysis
-
This ruling underscores the critical importance of age determination in cases of alleged sexual offences involving minors.
-
The Court emphasized due process and evidentiary standards, particularly when the only age proof (birth certificate and school record) is shown to be fabricated.
-
The judgment affirms that statutory presumptions under POCSO or IPC (like immateriality of consent) cannot be invoked without first establishing the victim’s minority.
-
It also flags a procedural lapse by the prosecution in failing to conduct a medical test, which could have provided corroboration.
-
The Court's analysis is grounded in the principle of benefit of doubt, and the accused’s constitutional right to fair trial.