Supreme Court Reinstates FIR Against Teacher Accused of Sexual Assault, Emphasizes Child Protection and Public Interest Over Private Compromise

Court’s Decision:

The Supreme Court quashed the Rajasthan High Court’s order that had dismissed an FIR against a teacher accused of sexually assaulting a minor student. The Court emphasized that offenses involving serious sexual allegations under the Protection of Children from Sexual Offences (POCSO) Act cannot be dismissed on the grounds of a private settlement between the accused and the victim’s family. The Supreme Court underscored the need for the judicial process to take its course in cases impacting public interest and societal norms.

Facts of the Case:

A complaint was lodged by the victim’s father, alleging that on January 6, 2022, the teacher had molested his daughter, a Class XI student, within the school premises. The accused allegedly touched the student inappropriately and used caste-based slurs. Despite opposition from the prosecution, the High Court quashed the FIR following a compromise between the teacher and the victim’s family, citing Gian Singh v. State of Punjab as precedent.

Issues:

1. Whether a third party has locus standi to challenge the High Court’s quashing order based on compromise in criminal proceedings.
2. Whether heinous offenses with societal impact can be quashed solely due to a private compromise between parties.

Petitioner’s Arguments:

The appellants contended that the accused’s alleged crimes were grave, impacting society at large and requiring judicial scrutiny. They argued that the High Court’s decision to quash the FIR based on compromise disregarded public safety and the victim’s right to justice, stressing that offenses under the POCSO Act are not of a private nature and thus cannot be dismissed based on family compromise alone.

Respondent’s Arguments:

The respondents argued against the appellants’ standing, asserting that the compromise with the victim’s father should allow quashing of the FIR. They cited precedents indicating that personal disputes resolved between parties, where public peace is not at stake, could justify the dismissal of criminal proceedings.

Analysis of the Law:

The Court reviewed the POCSO Act’s provisions, emphasizing the legislation’s aim to protect children and deter sexual offenses. It highlighted that the POCSO Act addresses inadequacies in existing laws regarding child protection, demanding strict judicial oversight for heinous crimes involving minors. The Court noted that offenses like molestation and sexual assault in educational settings are not merely private disputes but hold significant implications for society.

Precedent Analysis:

The Court examined Gian Singh v. State of Punjab, noting that while compromise could lead to quashing in certain cases, heinous crimes with societal implications, particularly those under special statutes like POCSO, should be viewed differently. Additionally, in State of M.P. v. Laxmi Narayan, the Court underscored that public offenses, especially those impacting vulnerable groups, cannot be trivialized or dismissed solely due to private settlement.

Court’s Reasoning:

The Court reasoned that child protection and public interest must be prioritized over private settlements in cases under the POCSO Act. It found the High Court’s decision deficient for not sufficiently addressing the serious nature of the allegations, disregarding the statutory intent of POCSO. Moreover, it emphasized that quashing the FIR without judicial assessment would undermine the victim’s rights and public trust in the justice system.

Conclusion:

The Supreme Court set aside the High Court’s order, reinstating the FIR and directing the investigation to proceed. The Court clarified that the judicial process must not be halted prematurely in cases involving crimes against minors, especially under the POCSO Act.

Implications:

This judgment reinforces the view that crimes impacting public morality and involving minors under the POCSO Act cannot be dismissed due to private settlements. It signals a strict stance on the judicial process in child protection cases, affirming that public safety and victim rights must prevail over family-based compromises in criminal cases.