Summary and Analysis of Satauram Mandavi vs. The State of Chhattisgarh (Criminal Appeal No. 3179/2025)

1. Heading of the Judgment

Satauram Mandavi vs. The State of Chhattisgarh & Anr.
(Supreme Court of India, Criminal Appeal No. 3179 of 2025)

2. Relevant Laws and Sections

• Indian Penal Code (IPC), 1860: Section 376AB (Rape of a child below 12 years).

• Protection of Children from Sexual Offences (POCSO) Act, 2012:
  Section 6 (Punishment for aggravated penetrative sexual assault).

• Constitution of India:
  Article 20(1) (Protection against retrospective punishment).

• POCSO (Amendment) Act, 2019: Enhanced punishment under Section 6 (effective from 16.08.2019).

3. Basic Case Details

• Parties:
  Appellant: Satauram Mandavi (convicted for raping a 5-year-old girl).
  Respondents: State of Chhattisgarh.

• Incident: On 20.05.2019, the appellant lured a 5-year-old girl to his house and raped her while her family attended a wedding.

• Trial Court (30.11.2021): Convicted under Section 376AB IPC and Section 6 POCSO Act. Sentenced to life imprisonment till natural death + ₹10,000 fine.

• High Court (05.09.2023): Upheld conviction and sentence.

• Supreme Court Appeal: Limited to reduction of sentence (conviction not challenged).

4. Explanation of the Judgment

Key Issue

Whether the enhanced punishment under the POCSO (Amendment) Act, 2019 (effective 16.08.2019) could apply to an offence committed before the amendment (20.05.2019).

Court's Analysis

1. Constitutional Protection (Article 20(1))
   Article 20(1) bars retrospective application of harsher penalties.
   At the time of the offence (20.05.2019), the unamended Section 6 of POCSO Act prescribed:
   *"Rigorous imprisonment (minimum 10 years, up to life) + fine."*
   "Life imprisonment" meant conventional life (not necessarily till natural death).

2. Post-Amendment Law (16.08.2019)
   Amended Section 6 increased punishment to:
   "Minimum 20 years, extendable to life imprisonment till natural death."

3. Violation of Article 20(1)
   Imposing "life till natural death" (post-amendment) for a pre-amendment offence violates Article 20(1).
   Trial Court erred in applying the amended law retrospectively.

Decision

• Conviction upheld (under Section 376AB IPC and Section 6 POCSO).

• Sentence modified:
  "Life imprisonment till natural death" set aside.
  Rigorous imprisonment for life (as per pre-amendment law) imposed.
  Fine of ₹10,000 maintained.

Philosophical Basis

"The Constitution shields citizens from retrospective harsh penalties. While the crime is heinous, sentencing must align with the law at the time of offence."

Key Outcomes

1. Legal Principle:
   Article 20(1) prohibits enhanced punishment for past offences.

2. For the Case:
   Appellant to serve life imprisonment (not "till natural death").

3. Broader Impact:
   Reinforces that amendments increasing penalties apply prospectively.