Case Commentary On P. Yuvaprakash V. State, 2023 SCC Online SC 846

Aditya Rana, Jindal Global Law School

INTRODUCTION

The case of P. Yuvaprakash vs State Rep. By Inspector Of Police1 presents a complex legal scenario, unfolding a narrative of alleged offenses involving the appellant and invoking the provisions of the Protection of Children from Sexual Offences Act, 2012 (POCSO Act). The appellant, dissatisfied with the conviction and sentence affirmed by the Madras High Court, sought redress through an appeal. The legal intricacies of age determination, the reliability of statements made under Section 164 of the Criminal Procedure Code (Cr.PC), and the proper interpretation of the POCSO Act are central to the issues at hand. Against the backdrop of a complaint lodged by T. Abdul Hameed, the appellant stands accused of a series of events involving the purported abduction, marriage, and sexual intercourse with the victim, identified as "M." The trial court initially rendered a conviction, subsequently modified by the High Court, affirming the POCSO Act conviction while altering the sentence. This case commentary delves into the nuanced legal aspects, scrutinizing the evidence, evaluating age determination procedures, and dissecting the applicability of the POCSO Act in light of the presented facts. The intricate legal journey unfolds against the canvas of the victim's familial context, highlighting the contentions surrounding the circumstances leading to the allegations. The appellant's acquittal on charges under Section 366 of the Indian Penal Code (IPC) and the subsequent conviction under Section 6 of the POCSO Act underscore the need for a meticulous examination of the evidence presented during the trial. This case commentary aims to dissect the court's reasoning, critically analyse the legal arguments put forth by both the prosecution and the defence, and illuminate the broader implications of the court's decision on the application of laws pertaining to crimes against children.