School certificate date of birth prevails over medical ossification test reports for age determination under POCSO.

The Appellant was accused of enticing a minor girl (the victim) by misrepresenting his identity as "Ayan Jain"

The victim alleged that on 27.05.2023 and 14.07.2023, the Appellant took her to Barpeta and engaged in sexual intercourse, videographing the second instance and later circulating images on social media

The Trial Court (Special Judge, Chirang) convicted the Appellant under Section 6 of the POCSO Act (20 years RI) and Section 363 IPC (2 years RI)

The Appellant challenged the conviction, contending the relationship was consensual and the victim was a major based on medical ossification reports

1. Whether the victim was a minor on the date of the occurrence, and whether external medical evidence regarding age can override a school certificate

2. Whether the sexual acts between the Appellant and the victim constituted an offense despite the plea of consent

Section 94 of the Juvenile Justice (Care and Protection of Children) Act, 2015, which mandates a hierarchical approach to age determination, prioritizing school/matriculation certificates over medical tests

P. Yuvaprakash v. State (2024) 17 SCC 684, which established that medical age determination (ossification) is a last resort only in the absence of statutory documents

State of Uttar Pradesh v. Anurudh and Another (2026) regarding the limited mandate of medical determination of age

Under the POCSO Act, the consent of a minor is legally immaterial

The Court rejected the Appellant's reliance on medical evidence (estimating age at 19-21 years) because a valid school certificate (MO-1) showing the victim's date of birth as 20.03.2007 was available and unchallenged

Applying Section 94 of the JJ Act and the P. Yuvaprakash precedent, the Court held the school record conclusive, rendering the victim a minor (under 17) at the time of the incident

Consequently, the defense of "consensual relationship" was dismissed as consent is no defense for offenses against minors under POCSO

The Court found the victim to be a "sterling witness" whose consistent testimony regarding the sexual acts and the Appellant's use of an alias was not shaken during cross-examination

Procedural discrepancies regarding the place of occurrence (Guwahati vs. Barpeta) were deemed immaterial as they did not dilute the core testimony regarding the acts at Barpeta

The Gauhati High Court affirmed the Judgment and Order dated 25.02.2025 passed by the Special Judge, Chirang, maintaining the conviction under Section 6 of the POCSO Act and Section 363 IPC

The appeal was dismissed as devoid of merit