Satauram Mandavi v. The State of Chhattisgarh & Anr. (Arising out of SLP (Crl) No. 13834 of 2024), 2025
The retrospective application of the amended harsher punishment was violative of Article 20(1) of the Constitution, which prohibits retrospective imposition of a heavier penalty.
Judgement Details
Court
Supreme Court of India
Date of Decision
28 July 2025
Judges
Justice Vikram Nath ⦁ Justice Sandeep Mehta
Citation
Acts / Provisions
Section 13(1)(ia), Hindu Marriage Act, 1955
Section 25, Hindu Marriage Act, 1955
Facts of the Case
- The appellant was convicted for raping a 5-year-old minor and sentenced by the trial court to life imprisonment for the remainder of natural life under the amended Section 6 of the POCSO Act (post-2019 amendment).
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The conviction under Section 376AB IPC and Section 6 POCSO was upheld by the Chhattisgarh High Court, which also imposed a fine of Rs. 10,000.
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The appellant challenged only the sentence, arguing that the amended harsher penalty could not be applied retrospectively because the offence occurred before the amendment came into force.
Issues
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Whether the trial court could apply the amended provision of Section 6 POCSO retrospectively to impose life imprisonment for the remainder of natural life?
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Whether the retrospective application of the harsher penalty violated Article 20(1) of the Constitution, which bars retrospective imposition of increased criminal punishment?
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Whether the sentence of life imprisonment as per the unamended Section 6 (meaning imprisonment for life in the conventional sense) was appropriate?
Held
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The retrospective application of the amended harsher punishment was violative of Article 20(1) of the Constitution, which prohibits retrospective imposition of a heavier penalty.
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The sentence of life imprisonment till remainder of natural life did not exist at the time of the offence (May 20, 2019), so only the unamended provision applied.
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The sentence under the unamended Section 6 allows imprisonment for life in its conventional sense, not for the remainder of natural life.
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The trial court’s order was found contrary to constitutional safeguards under Article 20(1) and Article 21.
Analysis
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The judgment reinforces the constitutional protection against retrospective punishment for criminal offences, emphasizing the rule of law and fairness in sentencing.
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It distinguishes between the conviction and sentence, affirming that while the conviction stands, the punishment must conform to the law as it stood at the time of offence.
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The Court’s decision ensures that amendments to criminal laws with harsher penalties do not undermine fundamental rights by being applied retroactively.
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This ruling clarifies the interpretation of life imprisonment under the POCSO Act and protects against excessive sentencing that violates constitutional guarantees.