X Vs. State o U.P
It strengthens rights of child victims under POCSO Act for financial reparation.
Judgement Details
Court
Allahabad High Court
Date of Decision
19 January 2026
Judges
Justice Shekhar B. Saraf and Justice Manjive Shukla
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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Petitioner was a victim of penetrative sexual assault under POCSO Act.
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Claimed compensation of Rs. 3 lakhs under Uttar Pradesh Rani Lakshmi Bai Mahila Samman Kosh Rules, 2015.
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No compensation was paid; petitioner approached the High Court through her mother.
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Injury report did not mention any injuries.
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FIR and chargesheet disclosed the offence under Section 4 POCSO Act.
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Court relied on Dalip Kumar @ Dalli v. State of Uttaranchal, which held that sexual assault may occur without bodily injuries.
Issues
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Whether compensation under the Uttar Pradesh Rani Lakshmi Bai Mahila Samman Kosh Rules, 2015 can be denied due to absence of injuries in the injury report?
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Whether the steering committee can conduct a trial to dispute compensation when the FIR and chargesheet disclose offence under Section 4 POCSO Act?
Held
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Beneficial legislation must be interpreted liberally in favor of the victim.
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Payment of compensation is due once the FIR and charge indicate the offence under Section 4 POCSO Act.
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Steering committee cannot act as a fact-finding authority or deny compensation based on absence of injuries.
Analysis
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Reinforces principle that sexual assault can occur without bodily injuries.
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Highlights pro-victim approach in interpretation of beneficial schemes.
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Clarifies that administrative bodies cannot act as quasi-judicial fact-finders when statutory conditions for compensation are met.
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Strengthens rights of child victims under POCSO Act for financial reparation.