P.T. v. State of MP: POCSO Conviction Quashed Under Art 142

Supreme Court Quashes POCSO Conviction Under Article 142 as Victim and Accused Married During Trial

Published: 13 November 2026 · NyayVidhan · 3 min read

In P.T. v. State of Madhya Pradesh & Anr., the Supreme Court used Article 142 of the Constitution to quash the appellant's conviction and sentence under the POCSO Act and the IPC, the proceedings behind them and his pending appeal in the Madhya Pradesh High Court. The parties had married during the trial and live together as husband and wife. The Court acted on the case's peculiar facts and said the power ought to be invoked sparingly in serious crimes against children and women (paras 15-19).

Key holdings

The Court quashed a POCSO conviction and sentence under Article 142 because the parties married during the trial and live together (paras 16, 18).

In serious crimes, including crimes against children and women, Article 142 ‘ought to be invoked sparingly’ (para 15).

The victim's affidavit affirming that the marriage was voluntary weighed with the Court (para 16).

The High Court had refused to suspend the sentence, observing that the Article 142 power did not vest in it (para 7).

The pending High Court appeal was quashed along with the conviction (para 18).

Judgment digest by NyayVidhan: a summary of the court's judgment, not its text. The judgment itself is the authoritative version.

Brief Facts

The prosecution alleged that the appellant took the victim from her house and committed rape on her (para 3). On 30.05.2024 the Special Court convicted him under Sections 384 and 366 IPC and Section 3 read with Section 4(ii) of the POCSO Act, imposing up to 20 years' rigorous imprisonment (para 5). Pending his appeal, the Madhya Pradesh High Court refused on 29.10.2025 to suspend the sentence: noting the marriage, it found material that the victim was then a minor and observed that the Article 142 power did not vest in it (paras 6-7). The Supreme Court suspended it on 11.05.2026 (para 10). He also applied under Article 142 to set aside the conviction, citing the marriage (para 8).

Court's Findings

No objections were filed to the Article 142 application; the State asked for appropriate orders on it (paras 11-12). On 11.05.2026 the victim, now a major, had told the Court that she would reside with her husband, the appellant (para 10). The Court noted that the parties married during the criminal proceedings before the Trial Court and have lived together as husband and wife since, and found it a fit case to use Article 142 for the appellant and the victim (paras 13-14, 16). It recorded that in serious crimes, including crimes against children and women, the power ‘ought to be invoked sparingly’, only when the Court is convinced that justice will be served ‘in the truest sense’ (para 15). It relied on the victim's affidavit before the High Court affirming that the marriage was voluntary, and found that continued prosecution would impede the parties' matrimonial life (para 16). It extracted Ramawatar v. State of M.P. on Article 142 after conviction (para 17), then quashed the proceedings, the conviction and the sentence, and the High Court appeal (para 18). The order does not examine the evidence.

Legal Principle

The order lays down no wider rule. On peculiar facts, a marriage during the trial, life together as husband and wife and the victim's affidavit that the marriage was voluntary, the Court used Article 142, with the appeal still pending, to quash a POCSO conviction, stressing that the power is to be invoked sparingly (paras 15-19).

NyayVidhan's view · Practice note

Why It Matters

Read this order narrowly. The Court itself said that in serious crimes against children and women Article 142 ‘ought to be invoked sparingly’ (para 15), and it allowed the application ‘having regard to the peculiar facts and circumstances of the case’ (para 19): a marriage during the trial, life together since, the victim's affidavit that the marriage was voluntary, and an appeal still pending (paras 13-16). The High Court had observed that this power did not vest in it (para 7). The order does not discuss the evidence or hold the conviction wrong on the merits, and it extracts Ramawatar v. State of M.P. without applying its factors one by one (para 17).

Editorial comment by the NyayVidhan Editorial Desk. It is not part of the Court's judgment and is not legal advice.

Precedents Relied Upon

Ramawatar v. State of M.P. (2022) 13 SCC 635
Referred To Discussed at ¶ 17
Extracted on the invocation of Article 142 in post-conviction cases: criminal proceedings in non-heinous offences or offences predominantly of a private nature may be set aside at any stage, including the appellate stage; where a settlement is struck after conviction, courts must examine how the compromise was reached and the conduct of the accused; and the power is exercisable after conviction only while an appeal is pending. The Court then quashed the conviction in the peculiar facts of the case.