Summary and Analysis of SUA vs. State of Rajasthan

1. Heading of the Judgment

SUA vs. State of Rajasthan
Supreme Court of India
Criminal Appeal No. 2695 of 2025
Decision Date: 23 July 2025

2. Relevant Laws & Sections

• Indian Penal Code (IPC):
  Section 342: Wrongful Confinement
  Section 376: Rape

• Juvenile Justice Laws:
  Juvenile Justice (Care and Protection of Children) Act, 2000 ("2000 Act")
  Juvenile Justice (Care and Protection of Children) Rules, 2007 ("2007 Rules")

3. Basic Judgment Details

AspectDetailsAppellantSUA (convicted for rape and wrongful confinement)RespondentState of RajasthanLower Courts- Trial Court (1993): Conviction under Sections 342 & 376.
- High Court (2024): Upheld conviction.Key Issue1. Validity of conviction based on evidence.
2. Claim of juvenility at the time of offence (1988).OutcomeConviction upheld but sentence set aside; case referred to Juvenile Justice Board.

4. Explanation of the Judgment

A. Background of the Case

• The appellant was convicted in 1993 for:
  Wrongfully confining an 11-year-old girl (Section 342 IPC: 6 months’ jail + fine).
  Raping her (Section 376 IPC: 5 years’ jail + fine).

• The High Court confirmed this conviction in 2024.

• The Supreme Court appeal challenged both the evidence and raised a new claim: the appellant was a juvenile (16 years old) in 1988.

B. Appellant’s Arguments

1. Evidence Flaws:
   FIR filed 20 hours after the incident (17 Nov 1988).
   Victim’s brother turned hostile, claiming the case was false due to a land dispute.
   Medical report (PW-8) noted no external injuries and no fresh bleeding on the victim.

2. Juvenility Claim:
   Birthdate: 14 September 1972 → Age on incident date (17 Nov 1988): 16 years, 2 months.
   Cited Dharambir v. State (NCT of Delhi): Juvenility can be raised at any stage, even after conviction.

C. State’s Arguments

1. Conviction Valid:
   Victim’s testimony was consistent and credible.
   Medical evidence (potency test of appellant) and seized clothes (victim’s skirt, appellant’s underwear) supported guilt.
   Delay in FIR explained: Victim was 11, police station 26 km away, incident reported next morning.

2. Legal Precedent:
   Citing Mohd. Imran Khan v. State (NCT of Delhi): Conviction can rest solely on prosecutrix’s testimony if credible.

D. Supreme Court’s Findings

1. On Conviction:
   Victim’s testimony was "firm in cross-examination" and backed by medical/official witnesses.
   Hostile witnesses and minor contradictions did not weaken the prosecution’s case.
   Verdict: Conviction under Sections 342 & 376 IPC upheld.

2. On Juvenility:
   Inquiry ordered (Jan 2025) confirmed appellant’s birthdate (14 Sept 1972) via school records.
   Age on incident date: 16 years, 2 months → Juvenile under the 2000 Act.
   Citing Hari Ram v. State of Rajasthan: Juvenility plea can be raised at any stage, even after case disposal.
   Verdict: Sentence set aside as unsustainable for a juvenile.

E. Final Order

• Conviction upheld but sentence quashed.

• Case referred to the Juvenile Justice Board for fresh orders under Sections 15–16 of the 2000 Act.

• Appellant directed to appear before the Board on 15 September 2025.

Key Takeaways

1. Evidence Standards: Credible victim testimony + supporting evidence suffices for rape conviction even with hostile witnesses.

2. Juvenility Rights: Age-based benefits under juvenile laws can be claimed anytime, overriding procedural delays.

3. Legal Impact: Juveniles convicted pre-2000 are entitled to resentencing under the 2000 Act.