LegalAware
LegalAware.ai
EMPOWERING LEGAL AWARENESS

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.

Official source (sci.gov.in)View Judgment (PDF)

More rulings in Constitutional Law

Constitutional LawSupreme Court of India

Federation of Medical and Sales Representatives Associations of India & Ors. v. Union of India & Ors.

This is an interim order, not a final judgment. The Court recorded the Union of India's proposal to set up a fresh three-member Committee to examine the issue and recommend a regulatory or statutory framework. It directed the Union to constitute the Committee within two weeks, directed the Committee to consult the petitioners, intervenors and other stakeholders and report within two months of its first meeting, and asked the Union to file a compliance affidavit. Citing the separation of powers, the Court declined to decide for itself whether the Code should become law, and listed the matter on 29 January 2027.

Decided 8 Oct 2026Read case
Constitutional LawDelhi High Court

Sirajuddin Qureshi & Ors. vs. Union of India & Ors.

The Court held that a bank's fear that the petitioners might flee, or its unresolved financial claim, cannot by itself justify keeping an LOC alive indefinitely, especially where the petitioners' bail conditions impose no travel curbs and their track record shows no misuse. It quashed the LOCs issued at the banks' instance, while leaving the LOCs issued at CBI's instance to be addressed through an application before the trial court (since those criminal proceedings are still pending there).

Decided 7 Oct 2026Read case
Constitutional LawDelhi High Court

Lawyers Voice vs. Union of India & Ors. and connected matters

The Court dismissed the entire batch, holding that no exceptional circumstance justified registering further FIRs, setting up an independent investigative mechanism, ordering wholesale further investigation into police conduct, issuing blanket evidence-preservation directions, or granting further compensation or rehabilitation directions. It noted that more than six years had passed since the riots, that compensation had largely been disbursed, and that statutory remedies remained available to victims. The Court made clear this was without prejudice to any individual's right to pursue remedies in law, and dismissed the petitions with no order as to costs.

Decided 5 Oct 2026Read case
Constitutional LawDelhi High Court

Shayaan Mujeeb vs. State & Ors. and connected matters

The Court dismissed the entire batch of petitions after finding that the allegations about the December 2019 events had already been examined by a competent statutory body and were being investigated under the ordinary criminal law, with related proceedings pending before competent courts. The Court held there was no ground for an independent inquiry mechanism, transfer of investigation, registration of new criminal cases, award of compensation, fresh guidelines, or further consequential directions. It also held that Article 226 of the Constitution is meant for enforcing enforceable legal rights, not for open-ended directions. The petitions were dismissed with no order as to costs, and any individual may still pursue remedies available in law.

Decided 5 Oct 2026Read case
Constitutional LawDelhi High Court

Pushpendra Singh Parmar vs. President/Vice President/General Secretary, ICSI

The Court held that the dispute was, at its core, a personal grievance between the petitioner and a private company (UC Web Mobile Pvt. Ltd.), not a matter properly brought before the Court under Article 226's extraordinary writ jurisdiction. It held that Article 226 is not meant to be a forum for airing personal disputes or pursuing a private adversary merely because a representation went unanswered. The petition was dismissed, with liberty given to the petitioner to pursue appropriate legal remedies directly against the company.

Decided 29 Sept 2026Read case
Constitutional LawDelhi High Court

Glenmark Pharmaceuticals Limited & Anr. vs. Union of India & Ors.

Relying on its own 2025 ruling on a near-identical earlier notification concerning the same drug combination, the Court held that since the notification used the word "shall" without any express provision for retrospective effect, and took effect only upon Gazette publication, it operates prospectively from 18.08.2026 and cannot be applied to stock manufactured earlier. The Court disposed of the petition on terms: Glenmark must label all stock made after 18.08.2026, publish clear public notices in one English and one Hindi national newspaper and issue advisories to doctors, chemists and retailers within two weeks, and file an affidavit detailing pre-notification stock within four weeks, subject to which no coercive recall action under Section 28B would be taken against it.

Decided 18 Sept 2026Read case