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Madras High Court
Criminal Law

Kannan v. State — Madras High Court Holds Exhibiting Private Parts to Minor Child Not Sexual Assault But Sexual Harassment Under POCSO Act, Modifies Sentence

The Madras High Court has held that exhibiting one's private parts to a minor child, without physical contact, does not constitute sexual assault under Section 7 of the POCSO Act but falls under sexual harassment punishable under Section 11, and reduced the appellant's sentence accordingly.

Court
Madras High Court
Case / Citation
Crl A (MD) No. 523 of 2019
Date of Decision
September 10, 2026
Bench
Justice S Karthikeyan (Madurai Bench)
Parties
Kannan v. State
Relevant Acts & Sections
Sections 7 and 11(i), Protection of Children from Sexual Offences (POCSO) Act, 2012
Area of Law
Criminal Law
Headnotes
An 11-year-old boy playing on a terrace was taken by a plumber working there to a nearby room, where the man exposed his genitals and made a sexual request. The boy resisted and reported the incident to his mother, who contacted Childline. The trial court had convicted the man of sexual assault under Section 7 of the POCSO Act.

Full Judgment Text

FACTS:

An 11-year-old boy was playing on the terrace of a building where the appellant, a plumber, was working. The appellant allegedly took the child to a nearby room, removed his clothing, exposed his genitals, and asked the boy to perform a sexual act. The child resisted and reported the incident to his mother, who contacted Childline.

The trial court convicted the appellant under Section 7 of the POCSO Act (sexual assault) and sentenced him to three years' rigorous imprisonment along with a fine of ₹5,000. The appellant challenged the conviction and sentence before the Madurai Bench of the Madras High Court.

COURT'S ANALYSIS:

Justice S Karthikeyan examined the distinction between "sexual assault" under Section 7 and "sexual harassment" under Section 11 of the POCSO Act. The Court held that Section 7 requires physical contact of a sexual nature with the child, whereas the appellant's conduct — exposing his genitals to the child without touching him — did not meet that threshold.

The Court observed: "Though the said act would not attract the offence punishable under Section 7 of the POCSO Act, it would fall under Section 11(i)," which criminalises exhibition of a sexual organ to a child as sexual harassment.

HOLDING:

The Madras High Court modified the conviction from Section 7 to Section 11(i) of the POCSO Act, and correspondingly reduced the sentence from three years' to one year's rigorous imprisonment, along with the ₹5,000 fine, granting credit for time already served.

Source: LiveLaw, "Exhibiting Private Parts To Minor Child Not Sexual Assault But Sexual Harassment: Madras High Court Modifies Sentence," September 10, 2026.

Cases Cited & References

  1. 1. 2026 LiveLaw (Mad) 436
Nyay Vidhan
Court Judgments · 2 min read
Decided: September 10, 2026 Justice S Karthikeyan (Madurai Bench)
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