Medical opinion regarding age variation and prolonged silence in an alleged sexual relationship necessitate acquittal based on benefit of doubt.

The appellant was convicted by the learned Sessions Judge-cum-Special Judge, Sonepur, on 29.11.1997 for offences under Section 376 IPC and Sections 3(1)(xi) and 3(1)(xii) of the SC & ST (POA) Act, 1989

The prosecution alleged that on 11.01.1995, the appellant forcibly committed sexual intercourse with the victim (P.W.5), a member of a Scheduled Tribe working as a maid servant in his father’s house

It was further alleged that the relationship continued under a false promise of marriage, resulting in pregnancy

The appellant denied the charges, citing village rivalry. The victim’s age was a point of contention, with medical estimates varying between 14 and 18 years

The High Court called for a welfare report in 2026, noting the victim and her son are currently self-sustaining

1. Whether the victim had attained the age of consent as provided under Section 376 IPC at the time of the commission of the offence

2. Whether the accused had obtained "the consent" from the prosecutrix by playing fraud, coercion, or threat of any kind

3. Whether the conviction under the SC & ST (POA) Act was sustainable in the absence of evidence of caste-based intention

Section 376 of the Indian Penal Code regarding rape and Sections 3(1)(xi) and 3(1)(xii) of the SC & ST (POA) Act

Principle from Bishnudas Behera v. State of Orissa that ossification tests are not exact and a margin of 2–3 years variation must be considered

Benefit of doubt doctrine from Pradeep Kumar v. State of Chhattisgarh, holding that if two views are possible, the one favourable to the accused must be adopted

Legal principles regarding delayed reporting in consensual-type relationships as cited in Vijayan v. State of Kerala and Kaini Rajan v. State of Kerala

Requirement of proof that the offence was committed on the ground that the victim belonged to a protected community as established in Masumsha Hasanasha Musalman v. State of Maharashtra

The court found the prosecution's evidence regarding the victim's minority inconclusive. P.W.2 (Radiologist) estimated her age at 14–15 years but admitted a two-year margin of error, while P.W.7 estimated it at 16–18 years; thus, she could have been a major at the time of the incident

Regarding consent, the court noted the prosecutrix admitted to prior "intimate pleasantries" and continued the relationship for five months without raising an alarm or informing her parents during frequent visits home

The court determined the conduct was inconsistent with forcible rape and suggested a consensual relationship that soured after a failed marriage promise

The charges under the SC & ST Act failed because the relationship arose from proximity in the household rather than an intent to exploit the victim's tribal identity

The court set aside the judgment dated 29.11.1997 and acquitted the appellant of all charges under Section 376 IPC and Sections 3(1)(xi) and 3(1)(xii) of the SC & ST (POA) Act, granting him the benefit of doubt. The Criminal Appeal was allowed