Chhattisgarh High Court Upholds Life Sentence in Minor Sexual Assault Case, Cites DNA Evidence

News Citation : 2026 LN (HC) 271 | 2026:CGHC:18098-DB

April 21, 2026 : The High Court of Chhattisgarh has dismissed a criminal appeal and upheld the conviction and life sentence of a man found guilty of repeatedly sexually assaulting a minor, affirming the judgment of a Special POCSO Court in Raipur.

The Division Bench of Chief Justice Ramesh Sinha and Justice Ravindra Kumar Agrawal held that the prosecution had proved its case beyond reasonable doubt through consistent ocular, medical, and scientific evidence, and found no illegality or perversity in the trial court’s findings.

The case stemmed from a complaint lodged in September 2020 by the victim, who was found to be a minor at the time of the incident. She alleged that the accused had subjected her to repeated sexual assault over several months under threat. Medical examination later confirmed that she was pregnant, and she subsequently gave birth to a child. DNA analysis conclusively established that the accused was the biological father.

The trial court had convicted the appellant under provisions of the Indian Penal Code and the Protection of Children from Sexual Offences Act, 2012, sentencing him to imprisonment for the remainder of his natural life. Challenging this, the appellant argued before the High Court that the prosecution failed to prove the victim’s age, that her testimony contained inconsistencies, and that there was unexplained delay in lodging the FIR.

Rejecting these submissions, the High Court held that the victim’s testimony was cogent, consistent, and trustworthy, and could independently sustain conviction. It noted that her account was corroborated by her mother’s testimony and supported by medical evidence establishing pregnancy during the relevant period. The DNA report, the Court observed, provided “clinching” scientific corroboration linking the accused to the offence.

On the question of age, the Bench held that school records, including admission registers and marksheets, duly proved through a competent witness, were sufficient to establish that the victim was below 18 years at the time of the incident. The Court also relied on oral testimony of the victim and her mother, noting the absence of any rebuttal evidence from the defence.

Addressing the delay in reporting, the Court accepted the prosecution’s explanation that the victim remained silent due to threats and psychological pressure, observing that such delay is not uncommon in cases involving sexual offences against minors.

The Bench reiterated that in cases of sexual assault, the sole testimony of the prosecutrix can form the basis of conviction if it inspires confidence, and does not require independent corroboration as a rule. In the present case, however, the testimony was further strengthened by medical and scientific evidence.

Finding no merit in the appeal, the Court affirmed the conviction and sentence imposed by the trial court and directed that the appellant continue to serve the sentence. It also informed him of his right to approach the Supreme Court through legal aid if required.

Case Reference : CRA No. 1607 of 2025, Santosh Kumar Sahu vs State of Chhattisgarh; For Appellant: Mr. N. Naha Roy, Advocate; For Respondent/State: Ms. Anusha Naik, Deputy Government Advocate.