Karnataka High Court Upholds POCSO Conviction but Modifies Juvenile’s Sentence; Compensation Enhanced to ₹3 Lakh

Aadrikaa Legal Services (ALS)- Law I Litigation I Arbitration

Date: 10.09.2026

Karnataka High Court Upholds POCSO Conviction but Modifies Juvenile’s Sentence; Compensation Enhanced to ₹3 Lakh

The Karnataka High Court has upheld the conviction of a person who was a juvenile at the time of the offence in a case involving allegations under the Protection of Children from Sexual Offences Act, 2012 (POCSO Act) and the Indian Penal Code, while modifying the custodial sentence and enhancing the compensation payable to the victim from ₹1 lakh to ₹3 lakh.

The matter was decided by Justice H.P. Sandesh in Criminal Revision Petition No. 1262 of 2018. The revision challenged the appellate order dated 20 August 2018 and the Juvenile Justice Board’s order dated 26 April 2018.

Background of the Case

• The prosecution alleged that the petitioner, who was a juvenile at the relevant time, had sexually abused a four-year-old child. The case was registered after the child’s mother lodged a complaint, and the prosecution examined 12 witnesses, including the victim, her mother and medical witnesses.
• The Juvenile Justice Board had convicted the petitioner under multiple provisions of the POCSO Act read with Sections 375 and 376 of the IPC and sentenced him to three years in a juvenile home, along with payment of ₹1 lakh to the victim.

Contradictory Medical Evidence Considered

• A major argument raised in revision concerned differences in the medical evidence.
• One doctor who examined the child shortly after the incident reportedly noticed swelling, while another doctor at Vanivilasa Hospital, who examined the child later, did not find such swelling or injury. The defence relied on this discrepancy to argue that the prosecution case was doubtful.
• The State, however, contended that the discrepancy was minor and that the immediate complaint, the testimony of the victim and her mother, and the first medical examination supported the prosecution case.
• The Court also noted that the FSL report did not detect seminal stains. However, the allegation itself was not one of penile penetration.

Court Finds No Evidence of Penetrative Sexual Activity

• While examining the evidence, the High Court observed that the medical and forensic materials did not suggest penetrative sexual activity.
• The Court also took into account the petitioner’s status as a juvenile at the time of the offence, as well as the fact that he was by then married and had two children.
• Instead of re-appreciating the entire evidence to disturb the conviction, the Court considered it appropriate to modify the sentence.

Sentence Modified; Compensation Increased to ₹3 Lakh

• The High Court modified the original sentence of three years.
• The petitioner had already undergone 117 days in custody, and the Court gave him set-off for that period. In lieu of the remaining custodial sentence, the Court enhanced the compensation from ₹1 lakh to ₹3 lakh, while expressly confirming the conviction.
• The petitioner had already deposited ₹1 lakh before the Trial Court and was directed to deposit the balance ₹2 lakh before the High Court.

Compensation to Be Secured for the Victim

• The High Court further directed that both the existing ₹1 lakh and the additional ₹2 lakh be placed in fixed deposits in the name of the victim girl for three years or until she attained majority, whichever was earlier.
• The victim’s mother was permitted to withdraw the quarterly interest on the fixed deposits for the child’s education.

Key Legal Takeaway

• The decision is significant because the Court adopted a balanced approach: it did not overturn the conviction, but modified the sentence in view of the petitioner’s juvenile status and the evidentiary circumstances, while strengthening the compensatory relief available to the victim.
• The judgment also shows that in revision proceedings involving juvenile offenders, courts may consider the rehabilitative dimension of juvenile justice while ensuring that the victim’s interests remain protected.

Conclusion

In Arunachalam @ Arun v. State of Karnataka & Anr., the Karnataka High Court confirmed the conviction but modified the sentence imposed upon the juvenile offender. The Court took note of the medical evidence, the absence of proof of penetrative sexual activity, the petitioner’s juvenile status and the period of custody already undergone.

The final result was that the custodial sentence was modified, 117 days of custody were given set-off, and compensation was enhanced from ₹1 lakh to ₹3 lakh, with the amount secured in fixed deposit for the victim’s benefit and education.

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Source: Karnataka High Court

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