Bombay High Court

Managerial facilitation of sexual services in a spa justifies framing human trafficking and immoral traffic charges.

MAHENDRA SALGAONKAR vs STATE OF GOA, THROUGH POLICE INSPECTOR CRIME BRANCH, RIBANDAR P.S. AND ANR

Bombay High CourtJUDGMENT: March 09, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The Petitioner, Mahendra Salgaonkar, was the owner-cum-manager of "Venus and Mars Salon-Spa-Body Care" in Mapusa, Goa

Source reference: p. 2, 7

Following a tip-off on August 9, 2014, the CID Crime Branch conducted a trap using a decoy customer

Source reference: p. 2

The decoy customer paid the Petitioner Rs. 1,500 for a massage and subsequently paid a female victim Rs. 500 for a "special/extra/hand massage," terms allegedly synonymous with prostitution

Source reference: p. 3, 7-8

Upon a signal from the decoy, the raiding party entered the premises, recovered the marked currency notes from the Petitioner’s cash counter and the victim, and found condoms in the room

Source reference: p. 3-4

The police rescued four victims and filed a charge-sheet against nine accused

Source reference: p. 4-5

By an order dated January 17, 2024, the Sessions Judge directed the framing of charges against the Petitioner under Sections 370, 370-A(2) of the IPC and Sections 3, 4, 5, and 7 of the Immoral Traffic (Prevention) Act, 1956 (ITPA)

Source reference: p. 1-2

The Petitioner approached the High Court to quash this order

Source reference: p. 1
02

Issues

1. Whether there exists sufficient prima facie material to frame charges against the Petitioner for human trafficking and immoral trafficking offenses

Source reference: p. 5, 12

2. Whether the statements of the victim girls, which do not explicitly allege forced sexual exploitation, entitle the Petitioner to discharge

Source reference: p. 8-9
03

Law Applied

Section 370 of the IPC, which defines trafficking and includes "sexual exploitation" within the definition of "exploitation," clarifying via Explanation 2 that the consent of the victim is immaterial

Source reference: p. 9

Sections 3, 4, 5, and 7 of the Immoral Traffic (Prevention) Act, 1956, relating to the operation of a brothel and living on the earnings of prostitution

Source reference: p. 2

P. Vijayan v. State of Kerala (2010), which established that the judge must only find if there is "sufficient ground for proceeding"

Source reference: p. 11-12

State of Rajasthan v. Ashok Kumar Kashyap (2021), which mandates that at the stage of framing charges, prosecution material must be assumed true

Source reference: p. 12
04

Reasoning

The Court rejected the Petitioner's argument that the victims’ stereotypical statements—claiming fixed salaries and voluntary work—negated the offenses

Source reference: p. 8-9

It reasoned that under Section 370 IPC, the consent of the victim is legally irrelevant

Source reference: p. 9

The Court found that the statement of the decoy customer, the recovery of marked currency notes (matching serial numbers) from both the Petitioner and a victim, and the presence of condoms provided sufficient prima facie evidence of a prostitution racket being run under the guise of a spa

Source reference: p. 7-8, 10

The Court distinguished the Petitioner’s case from that of the co-accused (customers) whose charges were previously quashed, noting that the Petitioner was the manager and licensee of the premises

Source reference: p. 11

The Court emphasized that at the stage of framing charges, it cannot conduct a "mini-trial" or enter into the pros and cons of the evidence, but must only determine if a case for trial is made out

Source reference: p. 12
05

Holding

The High Court dismissed the Petition and discharged the rule, upholding the Sessions Judge's order to frame charges

The Court held that there is sufficient material in the charge-sheet, specifically the decoy customer's statement and the seizure panchanama, to proceed with the trial against the Petitioner for offenses under the IPC and ITPA

Source reference: p. 12-13
Bombay High Court

Original Court PDF

MAHENDRA SALGAONKARvsSTATE OF GOA, THROUGH POLICE INSPECTOR CRIME BRANCH, RIBANDAR P.S. AND ANR

Bombay High Court · March 09, 2026

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