Ravindra s/o Laxman Narete vs State of Maharashtra, 2025
Mere expression of "I Love You" without sexual intent does not constitute sexual harassment under POCSO Act
Judgement Details
Court
Bombay High Court
Date of Decision
3 July 2025
Judges
Justice Urmila Joshi-Phalke
Citation
Acts / Provisions
Section 13(1)(ia), Hindu Marriage Act, 1955
Section 25, Hindu Marriage Act, 1955
Facts of the Case
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The appellant, Ravindra Narete, was accused of sexually harassing a minor girl, a student of Class 11, while she was returning home from tuition on October 23, 2015.
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According to the FIR, the accused approached her on a motorcycle and told her “I Love You” and insisted on knowing her name.
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The victim, scared by the incident, informed her parents. A complaint was filed, and criminal proceedings were initiated.
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The Sessions Court, Nagpur, convicted the appellant in 2017 and sentenced him to 3 years of rigorous imprisonment along with a fine of ₹5,000.
Issues
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Does merely saying "I Love You" to a minor amount to sexual harassment under Section 11 of the POCSO Act?
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Can sexual intent be inferred solely from verbal expressions without overt sexual acts or gestures?
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What evidentiary standards apply in determining sexual intent?
Held
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Expression of love, without more, does not amount to sexual harassment under the POCSO Act or IPC.
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Intent is a factual matter and must be inferred from all surrounding circumstances—not presumed.
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The conviction was set aside and the accused was acquitted of all charges.
Analysis
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The ruling marks a significant clarification on the interpretation of "sexual intent" under the POCSO Act and IPC.
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The Court drew a clear line between inappropriate behavior and criminal conduct by requiring intentional sexual overture for an act to qualify as sexual harassment.
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It emphasized judicial caution in criminalizing expressions without solid proof of malicious or sexual intent, especially when dealing with verbal expressions.
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This judgment balances the protection of minors with the principle of presumption of innocence, ensuring that minor social missteps are not criminalized without justification.
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However, the judgment also reiterates the importance of victim testimony, contextual assessment, and evidentiary scrutiny.