Establishing the Necessity of Conclusive Proof of Minority in Section 366-A IPC Convictions

Introduction

The case of Akula Raghuram v. The State of Andhra Pradesh (2025 INSC 185) was heard before the Supreme Court of India, involving a charge under Section 366-A of the Indian Penal Code (IPC). The appellant, Mr. Akula Raghuram, faced conviction for allegedly abducting a minor with the intent of marriage. The conviction and sentence had been affirmed by both the Trial Court and the Revisional Court. The Supreme Court was called on to examine whether the charge under Section 366-A could be sustained given the evidence presented, especially with respect to the victim’s age and the specific elements required under the law.

The key issues revolved around:

The necessity of proving the victim’s minority conclusively.
Whether any sexual or illicit intent had been established in law.
The credibility of the victim’s testimony and her alleged consent.
Evaluation of ordinariness and consistency of evidence, including expert (medical) testimony.

The appellant’s defense argued that the evidence was inconsistent, the victim’s date of birth was not conclusively proven, and there was no showing of sexual or illicit intention. On the other hand, the State contended the medical examination supported minority, making the victim’s consent irrelevant for the purpose of Section 366-A. This commentary sheds light on the rationale behind the Supreme Court’s reversal of the conviction and the new guiding principle the decision establishes regarding proof of minority in prosecuting such matters.

Summary of the Judgment

The Supreme Court ultimately allowed the appeal and acquitted the appellant of the charge under Section 366-A of the IPC. The Court concluded that there was insufficient evidence to prove that the victim was a minor at the material point in time. Although the prosecution introduced a medical officer’s opinion that suggested the victim was about 16 to 17 years of age, the Court noted that the doctor’s opinion could include a margin of error (plus or minus two years), meaning the victim might have been an adult. Moreover:

There was no direct or conclusive documentary evidence, such as a birth certificate or school record, to definitively prove the victim’s date of birth.
The victim’s statements were internally inconsistent, with contradictory versions about her travel and relationship with the accused.
The prosecution’s chain of evidence linking the appellant to an alleged abduction vehicle and any force exerted upon the victim was found to be inadequate.
No credible evidence of sexual intent or illicit purpose was demonstrated under Section 366-A.

As a result, the Supreme Court held that the conviction could not be sustained, primarily due to the lack of conclusive proof of the victim’s minority and the questionable reliability of her testimony and supporting evidence.

Analysis

1. Precedents Cited

The Judgment refers to the established principle that for any offense under Section 366-A IPC to hold, the prosecution must prove:

The victim was a minor (i.e., under 18 years of age at the time of the offense).
There was inducement to indulge in illicit intercourse or the accused had a clear unlawful intention, typically involving sexual exploitation or forced marriage.

Although the Court’s decision does not cite extensive names of previous rulings, it implies reliance on older precedents that clarify the standard of proof for establishing a victim’s minority. The rule is that age must be proved incontrovertibly or beyond reasonable doubt. Where doubt persists, the benefit must go to the accused.

2. Legal Reasoning

The Supreme Court’s reasoning can be broken down as follows:

Requirement of Conclusive Evidence for Victim’s Age: Neither a birth certificate nor any academic record was produced that could definitively prove the victim’s age. The medical test, based on ossification, was inconclusive and required a margin of error that could make the victim of legal age.
Failure to Show Illicit Purpose: The allegations revolved around the accused’s purported desire to marry the victim rather than any explicit act of sexual exploitation or forced sexual relationship. No concrete evidence was led about any sexual or immoral intent beyond the alleged abduction for marriage.
Inconsistencies in Witness Testimony: The victim’s statements about her travels with the accused, her opportunities to flee, and her knowledge of the accused’s marital status created contradictions. The alleged “abduction” was not corroborated by strong eyewitness testimony, nor identified with certainty (e.g., no link between the confiscated jeep and the accused).
Benefit of Doubt to the Accused: In criminal jurisprudence, if the evidence is inconclusive, the Court is bound to give the benefit of doubt to the accused. The Judgment reiterates this principle, emphasizing the prosecution’s burden in proving every element of the offense.

3. Impact

The repercussions of this Judgment on Indian criminal law and future prosecutions under Section 366-A are significant:

Heightened Evidentiary Burden: Courts are likely to demand stronger documentary evidence of an alleged victim’s minority. Relying primarily on medical opinions without cross-substantiating documents may not suffice.
Importance of Consistency in Testimony: Where there are multiple contradictions, and the victim’s narrative changes drastically across statements, courts may deem such testimony unreliable.
Constitutional Safeguards for Accused: This Judgment reinforces the notion that suspicion alone cannot result in a conviction; a higher level of precision and clarity is required to meet the “beyond reasonable doubt” standard.
Guidance to Investigative Agencies: The investigating authorities must gather clear, objective proof of minority, such as birth or school certificates, to avoid the risk of acquittal when the victim’s age becomes decisive.

Complex Concepts Simplified

Below are the key legal terms and concepts simplified for a clearer understanding:

Section 366-A IPC: A provision that criminalizes the act of enticing or taking away a minor girl (under 18) with the intent that she may be forced or seduced to have illicit intercourse with another person.
Minority (Under IPC): Under Indian criminal law, a girl under the age of 18 is considered a minor for the purposes of Sections dealing with abduction, kidnapping, and sexual offenses.
Ossification Test: A medical procedure involving X-rays of bones, used to estimate a person’s age. It is not definitive but provides an approximate range with a margin of error.
Benefit of Doubt: A criminal law principle requiring courts to acquit an accused if the prosecution fails to establish guilt beyond a reasonable doubt. Any significant uncertainty must favor the defendant.

Conclusion

In Akula Raghuram v. The State of Andhra Pradesh (2025 INSC 185), the Supreme Court set a pivotal precedent underscoring that proving the victim’s minority conclusively is critical, particularly under Section 366-A IPC where the charge strictly hinges on the victim’s legal age and an element of inducement for illicit intercourse. Reliance on a marginally inconclusive medical examination, absent supporting documentary proof, fell short of the requisite legal standard to uphold the appellant’s conviction.

This Judgment is an important addition to the jurisprudence on abduction and kidnapping offenses. It directs investigative agencies and prosecutorial authorities to build robust, corroborated evidence when dealing with allegations of forced or induced travel for unlawful purposes, especially regarding proof of a victim’s age. Above all, it reaffirms the central principle in criminal law: where there is doubt, the accused is entitled to an acquittal.