Supreme Court Modifies Conviction in Laxman Jangde Case from Penetrative Sexual Assault to Outraging Modesty
Absence of Evidence Leads to Reduced Sentences under IPC and POCSO Act
News Report:
In a significant judgment, the Supreme Court of India has modified the conviction of Laxman Jangde from penetrative sexual assault to outraging modesty and aggravated sexual assault. The decision was delivered on September 10, 2025, by a bench comprising Justices Ahsanuddin Amanullah and Joymalya Bagchi in Criminal Appeal No. 3958 of 2025.
The case, originally adjudicated by the High Court of Chhattisgarh, involved charges under Section 376AB of the Indian Penal Code (IPC) and Section 6 of the Protection of Children from Sexual Offences Act (POCSO Act). However, upon review, the Supreme Court found that the evidence did not support these charges. The absence of medical evidence and consistent statements from the victim led the apex court to modify the conviction.
The court held that the acts described by the victim constituted aggravated sexual assault under Section 9(m) of the POCSO Act and outraging modesty under Section 354 of the IPC. The trial court's presumption of penetrative sexual assault was found unsustainable, resulting in reduced sentences. Laxman Jangde will now serve concurrent sentences of five years rigorous imprisonment under Section 354 IPC and seven years under Section 10 of the POCSO Act.
The Supreme Court's decision underscores the importance of evidence-based convictions in cases involving serious charges like penetrative sexual assault. It highlights the need for careful examination of medical reports and victim statements in determining the nature of the crime.
The appellant's legal team, led by Senior Advocate Mr. Ranji Thomas, argued that the evidence did not satisfy the requirements for a conviction under the original charges. They contended that the actions described were more accurately characterized under Section 354 IPC and Section 9(m) of the POCSO Act, given the lack of penetration.
The respondent-state, represented by Mrs. Prerna Dhall and her team, maintained that the appellant had committed a grave offense under both the IPC and POCSO Act, emphasizing the victim's age and the nature of the crime.
Despite the gravity of the allegations, the Supreme Court's judgment reflects a meticulous approach to evaluating the evidence presented. The decision to modify the conviction and reduce the sentence is based on a thorough analysis of the facts and legal provisions.
The court has retained the fine of Rs. 50,000, which must be paid as compensation to the victim. This aspect of the judgment ensures that the victim receives some form of redress despite the reduction in the appellant's sentence.
This ruling not only modifies the legal consequences for Laxman Jangde but also sets a precedent for future cases where evidence of penetrative assault is contested. It highlights the judiciary's role in balancing justice with evidentiary integrity.
Bottom Line:
Conviction under Section 376AB IPC and Section 6 of the POCSO Act modified to conviction under Section 354 IPC and Section 10 of the POCSO Act in absence of evidence supporting penetrative sexual assault.
Statutory provision(s): Section 376AB IPC, Section 354 IPC, Section 6 POCSO Act, Section 10 POCSO Act, Section 9(m) POCSO Act
