Chaman Lal v. The State of Himachal Pradesh
Background
The accused was alleged to have repeatedly had non-consensual sexual intercourse with a mentally unwell young woman (prosecutrix) whom he met while grazing cattle, resulting in her pregnancy and the birth of a child; DNA testing confirmed he was the biological father. The trial court acquitted him, mainly because of delay in lodging the FIR and a finding that the prosecutrix was not mentally unsound. The State appealed, and the High Court reversed the acquittal, convicting him under Sections 376 and 506 of the IPC and sentencing him to seven years' rigorous imprisonment, relying on medical evidence that the victim had an IQ of 62 and mild mental retardation. The accused then appealed to the Supreme Court.
Decision Breakdown
The Supreme Court upheld the High Court's conviction, holding that the medical evidence regarding the victim's IQ and mental retardation was reliable and consistent despite some language-related discrepancies in how tests were administered, since IQ assessment also relies on activities and case history, not language alone. The Court held the High Court was right to reverse the acquittal based on proper re-appreciation of evidence. On sentencing, the Court noted the High Court had already imposed only the minimum prescribed sentence of seven years, and found no reason for leniency given that the accused had exploited a mentally vulnerable victim. The appeal was dismissed and the conviction and sentence were upheld.
Lesson Learnt
Appellate courts can reverse an acquittal where reliable medical evidence establishes a victim's mental incapacity to consent, and taking advantage of someone's mental disability for sexual assault will not attract leniency in sentencing.