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Legal Case Shots

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Constitutional LawSupreme Court of India

Satauram Mandavi v. The State of Chhattisgarh

Criminal Appeal · 2025 INSC 892Decided 25 Jul 2025
Criminal Appeal arising out of SLP (Crl.) No. 13834 of 2024
Justice Vikram Nath · Justice Sandeep Mehta

Background

On 20.05.2019, the appellant lured a five-year-old girl into his house in Kondagaon district, Chhattisgarh, and raped her while her parents were away at a family wedding. He was convicted by the Trial Court under Section 376AB IPC and Section 6 of the POCSO Act and sentenced to imprisonment for life meaning imprisonment for the remainder of his natural life, plus a fine; the Chhattisgarh High Court affirmed both conviction and sentence. Before the Supreme Court, the challenge to conviction failed, but the appellant argued that the sentencing courts had wrongly applied the enhanced punishment introduced by the POCSO (Amendment) Act, 2019, which came into force on 16.08.2019, after the date of the offence.

Decision Breakdown

The Supreme Court agreed with the appellant on the sentencing point: since the offence occurred on 20.05.2019, before the 2019 Amendment (effective 16.08.2019) came into force, the unamended Section 6 of the POCSO Act (which prescribed "imprisonment for life" in its ordinary sense, not the amended definition of life imprisonment meaning the remainder of natural life) was the applicable law. Applying the amended, harsher provision to an offence committed before it took effect violated the absolute constitutional bar under Article 20(1) against being subjected to a penalty greater than what was permissible under the law in force at the time of the offence. The Court upheld the conviction but modified the sentence to rigorous imprisonment for life (in the conventional sense, allowing for remission per applicable rules) rather than imprisonment for the entire remainder of natural life, while maintaining the Rs. 10,000 fine.

Lesson Learnt

A person can only be punished under the law as it stood on the date the offence was committed: later amendments that increase the severity of punishment cannot be applied retrospectively, even in the most serious cases, because of the constitutional protection against retrospective or enhanced criminal penalties.

Satauram Mandavi v. The State of Chhattisgarh – Legal Case Shots | LegalAware