AI Overview...
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Manak Chand v. State of Haryana (2023 SCC Online SC 1397) - The Supreme Court emphasized the importance of reliable evidence to establish the age of the prosecutrix in cases of sexual offenses. The Court noted that without concrete proof, such as bone ossification tests, assumptions about age cannot be conclusively made. The judgment highlighted that the prosecution's evidence must inspire confidence and meet the standards of legal sufficiency. [Reference: Ganga Ram VS State Of Chhattisgarh through P. S. Darri - Chhattisgarh, Paranthaman vs The State of Tamil Nadu - Madras]
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Legal Precedents and Evidence Standards - The Court reiterated that in cases involving minors, especially under the POCSO Act, proof of age is critical. The absence of satisfactory evidence, like medical tests, can lead to acquittal, as seen in prior judgments. The Court also discussed the importance of the victim's testimony and the need for corroborative medical evidence to establish age reliably. [References: Ganga Ram VS State Of Chhattisgarh through P. S. Darri - Chhattisgarh, Paranthaman vs The State of Tamil Nadu - Madras, State Of Chhattisgarh Through District- Magistrate, District- Surguja, Chhattisgarh. vs Devlal S/o Pancham Ram - Chhattisgarh]
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Family and Settlement Dynamics - Some sources mention initial family negotiations and agreements for marriage between the prosecutrix and Manak Chand, indicating social and familial considerations. However, these did not outweigh the evidentiary requirements for conviction. [References: Manak Chand @ Mani VS State of Haryana - Supreme Court, MANAK CHAND @ MANI vs THE STATE OF HARYANA - Supreme Court]
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Judicial Approach - The Supreme Court has consistently held that the quality and reliability of evidence are paramount. It has criticized courts that rely solely on assumptions or incomplete evidence regarding age, emphasizing the need for scientific methods like ossification tests. The Court has also stressed that acquittals should be reconsidered if the prosecution's evidence is found credible and compelling. [References: ABDUL SALAM vs THE STATE OF KERALA - Kerala, State Of Chhattisgarh Through District- Magistrate, District- Surguja, Chhattisgarh. vs Devlal S/o Pancham Ram - Chhattisgarh, MOHANRAJ @ MOHAN vs THE STATE REP BY ITS - Madras]
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Conclusion - The Supreme Court's rulings in Manak Chand cases underscore the necessity for concrete, scientific, and trustworthy evidence to prove the age of minors in sexual offense cases. Mere assertions or family agreements are insufficient without corroborative medical proof, ensuring justice is based on substantive proof rather than assumptions. The Court maintains a strict standard to prevent wrongful convictions or acquittals based on unreliable evidence. All sources
Search Results for "Manak Chand Va State of Haryana"
2024 0 Supreme(Chh) 322 • India - Chhattisgarh
SANJAY KUMAR JAISWAL
State of Haryana, 2023 SCC Online SC 1397, emphasizing the requirement for reliable evidence to prove the age of the prosecutrix. ... The judgment referred to the law laid down by the Supreme Court in the matter of Manak Chand alias Mani v. ... In support of his submission, he referred the judgment rendered by the Hon’ble Supreme Court in the matter of Manak Chand alias Mani v. State of Haryana, 2023 SCC Online SC 1397. ... The Supreme Court in the m....
2023 7 Supreme 381 • India - Supreme Court
SANJAY KISHAN KAUL, C. T. RAVIKUMAR, SUDHANSHU DHULIA
Order of Trial Court dated 03.09.2001 has been upheld by High Court of Punjab and Haryana as per Judgment dated 19.02.2014 in appeal ... The order of the Trial Court dated 03.09.2001 has been upheld by the High Court of Punjab and Haryana as per judgment dated 19.02.2014 in appeal. 2. ... Initially, considering the relations between the families, the matter was being “settled” and the two families had even agreed for the marriage of the prosecutrix with the appellant Manak Chand @ Mani. ... More than a month later, the p....
2023 Supreme(Online)(SC) 19745 • India - Supreme Court
SUDHANSHU DHULIA, SANJAY KISHAN KAUL, C.T.RAVIKUMAR, JJ
The order of the Trial Court dated 03.09.2001 has been upheld by the High Court of Punjab and Haryana as per judgment dated 19.02.2014 in appeal. ... Initially, considering the relations between the families, the matter was being “settled”, and the two families had even agreed for the marriage of the prosecutrix with the appellant Manak Chand @ Mani. ... State of Madhya Pradesh (2008) 15 SCC 133 held as under: “10. ... He then gave a proposal before the parents of the appellant for marriage of the prosecutrix with the ap....
2025 Supreme(Online)(Ker) 23223 • India - IN THE HIGH COURT OF KERALA AT ERNAKULAM
C.S. Sudha, J
In support of the arguments, reference was made to the dictum in Manak Chand @ Mani v. State of Haryana , AIR 2023 SC 5600 . ... In Manak Chand @ Mani (Supra), the appellant therein aged 20 years, was alleged to have raped a girl who was stated to be under 16 years of age. However, there was no satisfactory evidence to show that the prosecutrix was under 16 years old at the time of the commission of the offence. ... On examination he found discolouration on the buttocks of the boy who ....
2025 Supreme(Online)(Del) 7440 • India - IN THE HIGH COURT OF DELHI AT NEW DELHI
DR. SWARANA KANTA SHARMA, J
In Manak Chand v. ... In case of Manak Chand v. State of Haryana (supra), the Supreme Court in similar circumstances, had observed that a bone ossification test ought to have been conducted in order to reach some reliable conclusion as to the age of the prosecutrix. ... In contrast, it would be relevant to take note of the three-Judge Bench decision of the Hon’ble Supreme Court in Manak Chand v. ... State of Haryana#HL....
2025 Supreme(Online)(Chh) 9564 • India - IN THE HIGH COURT OF CHHATTISGARH AT BILASPUR
Deepak Kumar Tiwari, J
The Supreme Court in the matter of Manak Chand alias Mani vs. State of Haryana 1, has reiterated the law laid down by it in the matter of Birad Mal Singhvi vs. ... Learned counsel for the State/appellant would submit that the trial Court has not appreciated the evidence in its proper perspective and prays to allow the appeal. ... When a query was put to counsel for the State, who after going through the impugned judgment submits that learned trial Court has not discussed this part of t....
2025 Supreme(Online)(Mad) 56570 • India - IN THE HIGH COURT OF JUDICATURE AT MADRAS
Dr. Justice R.N. Manjula, J
The latest judgment of the Supreme Court in Manak Chand @ Mani vs., State of Haryana, the Court has once again emphasized the significance of the quality of the evidence of the prosecution, which needs to inspire the confidence of the Court and in that case, the Court shall not look ... With regard to the evidentiary value of the evidence of victim, the law is well settled by the Hon'ble Supreme Court in the case of State of Punjab vs., Gurmit Singh reported in 1996 (2) SCC 384. ... of the victim girl ....
2024 Supreme(Online)(MAD) 15248 • India - High Court of Madras
M.S. RAMESH, J
[emphasis supplied] (iii) In yet another case in Manak Chand @ Mani v. State of Haryana, reported in 2024 (1) MWM (Crl) 255 (SC), the Hon'ble Supreme Court had held as follows: para 8 and 9. ... The State of Madhya Pradesh, reported in 1955 SCC OnLine SC 34 and Mohan Singh v. State of Bihar, reported in (2011) 9 SCC 272. ... Section 30 of the POCSO Act, reads as follows: “(1) In any prosecution for any offence under this Act which requires a culpable mental state on....
2025 Supreme(Online)(TRI) 43 • India - IN THE HIGH COURT OF TRIPURA AT AGARTALA
T. AMARNATH GOUD, BISWAJIT PALIT
Datta, learned counsel has placed reliance on the judgment of the Hon’ble Supreme Court in Manak Chand alias Mani vs. State of Haryana, 2023 SCC OnLine SC 139. ... State of Haryana, AIR 2013 SC 2071. The relevant contents of the said judgment as referred by the learned counsel is quoted herein-below: “......18. Consent may be express or implied, coerced or misguided, obtained willingly or through deceit. ... PP appearing for the State-respondent. 2. This present appea....
2025 Supreme(Online)(Chh) 9563 • India - IN THE HIGH COURT OF CHHATTISGARH AT BILASPUR
Deepak Kumar Tiwari, J
This Acquittal Appeal under Section 378 (1) of the Code of Criminal Procedure, 1973 has been preferred by the State against the judgment ... State of Haryana , [2023 SCC Online SC 1397], has reiterated the law laid down by it in the matter of Birad Mal Singhvi vs. Anand Purohit [1988 (Supl.) ... 11.The Hon'ble Supreme Court in the matter of Manak Chand alias Mani vs. ... Being aggrieved by the judgment of acquittal, the State has preferred the instant appeal. 6. ... Heard learned cou....
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