Sheikh Rafique Sk Gulab vs. State of Maharashtra (2025)

Bombay High Court upholds conviction in sexual assault case, rules child’s credible testimony sufficient for POCSO conviction.
Bombay High Court

Legal provision involved: Section 7, 8 and 42 of POCSO Act, Section 354 and 354A of IPC

Judgement by: Bombay High Court

Judge/Bench: Justice Nivedita P Mehta

Facts

A man was convicted for the sexual assault of a 13-year-old girl under the POCSO Act and the Indian Penal Code. The accused repeatedly approached the minor, offering her money for sexual activity, and on one occasion, physically held her hand while making a sexually explicit request. The minor reported the incident, leading to his conviction and imprisonment.

Key legal provisions involved

Issues raised

  1. Whether minimal physical contact accompanied by a sexual proposal amounts to “sexual assault” under Section 7 of the POCSO Act?
  2. Whether the conviction could be sustained on the sole testimony of a child without independent corroboration?

Arguments of the case

The defence argued there was no clear sexual intent and highlighted inconsistencies, lack of technical evidence, and a hostile witness. The prosecution maintained that the child’s testimony was credible, consistent, and supported by immediate disclosure and surrounding circumstances.

Judgement

The Bombay High Court upheld the conviction, emphasizing that sexual intent, not the extent of physical contact, defines the offence under Section 7. It ruled that credible testimony from a child victim is enough for conviction, affirmed the POCSO Act’s stricter punishment, and denied probation due to the offence’s seriousness.

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