Supreme Court of India

State of Maharashtra v Bandu @ Daulat

(2018) 11 SCC 163

Ratio Decidendi

The court reiterated the guidelines laid down in Sakshi v Union of India and mandated their implementation by January 2018. It emphasized the necessity of creating a conducive environment for vulnerable witnesses to provide their statements with special guidelines for child survivors of sexual abuse. It directed that special centres for the examination of vulnerable witnesses should be established in every district. The court also instructed all High Courts to adopt the Delhi Vulnerable Witness Deposition Complex Guidelines (‘VWDC Guidelines’), with modifications if necessary, and to take appropriate steps to establish these centres in phases.

Case Notes

Facts

The child survivor, aged 14 years, with hearing, speaking, and cognitive impairments, was sexually assaulted by the accused person, who was the landlord of her house and who had lured her away to the market using sweetmeat. She did not return home until much later and informed her mother about the abuse using gestures. An FIR was registered. The trial court convicted the accused under Section 376 of the IPC. However, the High Court acquitted the accused on the ground that since the child survivor herself was not examined, the factum of rape and involvement of the accused could not be held to have been proved. The State appealed the order of acquittal passed by the High Court.


Judgment

The Court restored the conviction of the accused and took note of the need to create conducive environments to encourage vulnerable witnesses to make their statements. In furtherance of this, the need for VWDCs was emphasised by the court. The Court took note of guidelines laid down in Sakshi v. Union of India and Ors. and Gurmit Singh. Additionally, The court directed for VWDCs to be set up in every district of the country in line with the guidelines for VWDCs issued by the Delhi High Court. The Court instructed all High Courts to take steps in this direction and ensure that their jurisdictions had at least two such centres in the next three months.

High Court of Delhi