Criminal appeal dismissed as no further adjudication survived after the appellant completed his sentence.

The appellant, the sole accused, filed a criminal appeal under Section 374 of the Code of Criminal Procedure, 1973, challenging the judgment dated 12 March 2018 in S.C. No. 307 of 2015 passed by the Special Court for Cases under the POCSO Act, 2012, Mahila Court, Chennai.

The Trial Court had convicted him under Section 5(h)(i)(m) read with Section 6 of the Protection of Children from Sexual Offences Act, 2012, and sentenced him to 10 years’ simple imprisonment and a fine of ₹5,000, with six months’ simple imprisonment in default.

During the appeal, the appellant submitted that he had already completed the sentence and had been released.

The prosecution produced prison records confirming that he was released from Central Prison-I, Puzhal, on 22 March 2025 after serving the sentence.

Whether the criminal appeal required further adjudication when the appellant had already served the sentence imposed by the Trial Court and had been released from prison.

Whether any further relief could be granted in the appeal against the conviction and sentence in the circumstances of the case.

The Court considered the appeal under Section 374 of the Code of Criminal Procedure, 1973, which provides for an appeal against conviction.

The conviction and sentence challenged in the appeal arose under Sections 5(h)(i)(m) and 6 of the Protection of Children from Sexual Offences Act, 2012.

The Court applied the procedural principle that where an appellant has fully undergone the sentence imposed and has been released, and no effective relief remains to be granted, the appeal may be dismissed as no longer requiring further adjudication.

The Court did not undertake a merits review of the conviction under the POCSO Act.

It relied on the appellant’s submission that he had completed the sentence and on the official prison proceedings confirming his release on 22 March 2025.

Since the custodial sentence had already been served, the Court concluded that no effective issue remained for adjudication in the appeal.

Accordingly, Criminal Appeal No. 222 of 2022 was dismissed.