Ajay Kumar Sharma vs Ut Of J&K And Others on 24 June, 2026

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    Jammu & Kashmir High Court

    Ajay Kumar Sharma vs Ut Of J&K And Others on 24 June, 2026

                                                                                 Sr. No. 41
    
            HIGH COURT OF JAMMU & KASHMIR AND LADAKH
                             AT JAMMU
    Bail App No. 78/2026 c/w
    CRM (M) No. 303/2026
                                    Date of pronouncement: 24.06.2026
                                    Date of uploading   : 03.07.2026
    Ajay Kumar Sharma                                       .....Applicant(s)/Petitioner(s)
    
                                    Through :- Mr. Dinesh Verma, Advocate
    
                             v/s
    UT of J&K and Others                                               .....Respondent(s)
    
                                    Through :- Mr. Sumeet Bhatia, GA
    
    
    CORAM:     HON'BLE MR. JUSTICE SANJAY PARIHAR, JUDGE
                                       ORDER
    

    CRM (M) No. 303/2026

    1. The petitioners seek quashment of FIR No. 0055/2026 dated

    SPONSORED

    21.02.2026 registered at Police Station Udhampur for offences

    punishable under Section 64(2) of the Bharatiya Nyaya Sanhita, 2023,

    read with Section 6 of the Protection of Children from Sexual

    Offences Act, 2012. The petitioners contend that they had been in a

    consensual love relationship since the year 2024, which was within

    the knowledge of the families of both parties. During the course of

    their relationship, they established physical relations, as a

    consequence whereof petitioner No. 2 conceived sometime in the year

    2025. Upon the families becoming aware of the pregnancy, it was

    mutually decided that the petitioners would solemnize their marriage

    immediately after petitioner No. 2 attained the age of majority, i.e., on

    21.01.2026. It was further decided that the pregnancy would be

    medically terminated; however, petitioner No. 2 did not consent to
    2 Bail App No. 78/2026 c/w
    CRM (M) No. 303/2026

    such termination. Thereafter, petitioner No. 2 delivered a female child

    at a hospital in Udhampur. According to the petitioners, it was only

    upon the birth of the child that the police-initiated action and

    registered the impugned FIR against petitioner No. 1. It is their

    specific case that although petitioner No. 2 had attained the age of

    majority at the time of delivery, the police proceeded to register the

    FIR on the premise that the conception had occurred while she was

    still a minor, despite being aware that the parents and members of the

    baradari of both parties had requested the police not to register any

    case and to treat the matter as closed.

    2. It is further pleaded that the petitioners solemnized their marriage in

    accordance with Hindu rites and ceremonies on 23.03.2026 at Arya

    Samaj, Janipur Colony, Jammu, in the presence of members of both

    families. On the strength of the subsequent marriage and the

    consensual nature of their relationship, the petitioners contend that the

    registration and continuation of the impugned FIR constitute an abuse

    of the process of law and have been initiated solely to harass them.

    3. This Court, vide order dated 01.04.2026, directed the Investigating

    Agency to proceed with the investigation but restrained it from filing

    the charge-sheet without obtaining prior leave of this Court.

    4. It is also averred that petitioner No. 1 is serving in the Army. He had

    approached the Court of the learned Principal Sessions Judge,

    Udhampur, seeking anticipatory bail; however, his application came to

    be dismissed vide order dated 17.04.2026. Aggrieved thereby,
    3 Bail App No. 78/2026 c/w
    CRM (M) No. 303/2026

    petitioner No. 1 has preferred Bail App No. 78/2026 before this Court

    seeking the relief of anticipatory bail.

    Bail App No. 78/2026

    1) In the bail application, the victim, who is also petitioner No. 2 in CRM

    (M) No. 303/2026, has been arrayed as respondent No. 3. On the

    previous dates of hearing, the Investigating Officer had appeared in

    person along with the Case Diary and was directed to ensure the

    presence of the victim before this Court. In compliance with the said

    direction, the victim appeared today accompanied by her uncle. She

    stated that she has now attained the age of majority. However, when

    queried as to whether she had consciously and voluntarily joined

    petitioner No. 1 in filing the petition seeking quashing of the FIR, she

    was unable to furnish any satisfactory explanation.

    2) A perusal of the Case Diary reveals that on 21.02.2026, the police

    authorities of Police Station Udhampur received information from the

    Government Medical College, Udhampur that an unmarried girl,

    namely the victim (petitioner No. 2 in CRM (M) No. 303/2026), had

    delivered a female child in the labour room. Verification of her

    Aadhaar Card disclosed her date of birth as 26.01.2008. Although she

    had attained the age of majority by the time the matter came to the

    notice of the police, it was evident that she had conceived while she

    was approximately 17 years of age. The attending circumstances prima

    facie indicated that she had been subjected to sexual intercourse during

    her minority, leading to the registration of FIR No. 0055/2026 dated
    4 Bail App No. 78/2026 c/w
    CRM (M) No. 303/2026

    21.02.2026 for offences punishable under Section 64(2) of the

    Bharatiya Nyaya Sanhita read with Section 6 of the Protection of

    Children from Sexual Offences Act.

    3) During the course of investigation, the statement of the victim was

    recorded under Section 183 of the Bharatiya Nagarik Suraksha

    Sanhita. In her statement, she alleged that in June, 2025, while she had

    gone alone to fetch water, petitioner No. 1 accosted her, gagged her by

    placing his hand over her mouth, forcibly removed her clothes and

    committed rape upon her. She further stated that the accused

    threatened her with dire consequences if she disclosed the incident to

    anyone. According to the victim, she conceived as a consequence of

    the said act but, owing to fear of the accused and social stigma, she did

    not disclose either the occurrence or her pregnancy to any member of

    her family.

    4) Case Diary further discloses that on 21.02.2026, when the victim

    developed labour pains, she informed her mother for the first time

    about the alleged incident of June, 2025. She was immediately taken to

    the Government Medical College, Udhampur, where she delivered a

    female child on the same day. Since the family of petitioner No. 1

    declined to accept the custody and responsibility of the newborn, the

    infant was subsequently handed over to the Child Welfare Committee,

    Udhampur.

    5) The Case Diary further reveals that petitioner No. 1, who is serving in

    the Army, has not joined the investigation despite repeated efforts
    5 Bail App No. 78/2026 c/w
    CRM (M) No. 303/2026

    made by the investigating agency. Various communications addressed

    to the Army authorities of JAKLI-11 requesting that the accused be

    made available to the investigating agency have not yielded the desired

    response. The investigating agency has specifically stated that

    obtaining the DNA sample of petitioner No. 1 is imperative for

    conducting scientific examination and comparison with the DNA

    profile of the child born to the victim. According to the Case Diary,

    such DNA profiling constitutes vital and indispensable scientific

    evidence for establishing the paternity of the child and for effectively

    investigating the allegations levelled against petitioner No. 1.

    6) Learned counsel for the petitioners argued that the present proceedings

    are nothing but an abuse of the process of law, as subsequent to the

    registration of the FIR, the parties solemnized their marriage on

    23.03.2026. In support of the said contention, reliance was placed upon

    the photographs appended with the petition, which, according to the

    petitioners, depict the presence of family members from both sides

    during the marriage ceremony. It was further contended that the case

    arises out of a consensual relationship between the parties. While

    conceding that petitioner No. 2 was a minor at the inception of their

    relationship, learned counsel vehemently argued that the victim herself

    has joined petitioner No. 1 in filing petition seeking quashment of the

    FIR. When confronted with the statement of the victim recorded under

    Section 183 of the BNSS, learned counsel says that the said statement

    was extracted under the influence and pressure of the investigating
    6 Bail App No. 78/2026 c/w
    CRM (M) No. 303/2026

    agency. According to him, the police, having found that the victim had

    conceived during her minority, deliberately fabricated the case,

    particularly when neither the victim’s father nor her mother had lodged

    any complaint with the police leading to the registration of the FIR.

    7) The respondents, however, contended that the allegations disclose the

    commission of serious offences involving sexual assault upon a minor

    girl. It was submitted that the victim, in her statement recorded before

    the learned Judicial Magistrate First Class under Section 183 of the

    BNSS, has narrated the incident in detail, thereby substantiating the

    prosecution case. It was further argued that since the alleged acts were

    committed during the minority of the victim, her consent, if any, is

    legally immaterial and cannot be recognized in law. Consequently, the

    petitioners’ attempt to invoke the so-called Romeo-Juliet principle does

    not absolve petitioner No. 1 of criminal liability, particularly when the

    victim was admittedly a minor at the relevant point of time.

    8) It was further submitted that the investigation is still in progress and

    that collection of DNA samples is an essential and crucial step in the

    investigation. Since petitioner No. 1 himself admits that he was in a

    romantic relationship with the victim, his DNA sample assumes

    significant evidentiary value for the purposes of forensic examination.

    According to the respondents, despite repeated opportunities, petitioner

    No. 1 has failed to join the investigation and submit to DNA profiling,

    thereby obstructing and frustrating the completion of the investigation,
    7 Bail App No. 78/2026 c/w
    CRM (M) No. 303/2026

    which is otherwise stated to be substantially complete except for

    obtaining the requisite DNA samples.

    9) After giving thoughtful consideration to the submissions advanced at

    the Bar, it emerges that the alleged incident took place in June 2025, at

    the relevant point of time, she is stated to have been between 17 and 18

    years of age. However, according to the prosecution, her date of birth,

    as reflected in her matriculation certificate, is 20.01.2008.

    Consequently, by the time the FIR came to be registered on

    21.02.2026, she had already attained the age of majority.

    10) The victim has alleged that the accused subjected her to sexual

    intercourse against her will and without her consent while she was still

    a minor. She reiterated these allegations in her statement recorded

    before the learned Magistrate. However, subsequently, on 30.03.2026,

    she joined hands with the accused-petitioner and filed a petition before

    this Court seeking quashing of the FIR.

    11) Significantly, the averments made in the joint petition are not entirely

    inconsistent with the statement made by the victim before the learned

    Magistrate. On the one hand, she has made allegations against the

    accused during the investigation, while on the other, it is alleged that

    she solemnized marriage with petitioner No. 1 at Arya Samaj, Janipur

    Colony, Jammu on 23.03.2026. Learned counsel appearing for the

    respondents contended that the alleged marriage has been projected

    only with a view to escape the rigours of criminal prosecution.

    Although, at first blush, the said contention appears attractive, there is
    8 Bail App No. 78/2026 c/w
    CRM (M) No. 303/2026

    no dispute that the FIR was not lodged at the instance of the victim or

    her family. It was only after the victim delivered a baby girl in the

    hospital on 21.02.2026 that the police set the criminal law into motion,

    on its own. The respondents have further asserted that the petitioner’s

    claim that the families of both parties had consented to the marriage is

    wholly false. Had that been so, according to the respondents, the

    parents of the victim would not have supported the prosecution case

    during the course of investigation. The accused, however, has

    controverted this assertion by alleging that the police, with a view to

    justify the registration of the FIR, prevailed upon the victim as well as

    her parents to make statements favourable to the prosecution. It has

    been further argued on behalf of the accused that the entire

    investigation is tainted and that the sole object of the investigating

    agency is to secure the arrest of petitioner No. 1 and subject him to

    unnecessary harassment.

    12) If there had been any substance in the allegation that the relationship

    between the parties was entirely involuntary or coercive, it would be

    difficult to comprehend why the parties chose to solemnize their

    marriage after petitioner No. 2 had admittedly attained the age of

    majority.

    13) It is in the aforesaid background that both the petitions require

    consideration. Insofar as CRM (M) No. 303/2026 is concerned, both

    the petitioners, including the victim herself, seek quashing of the FIR.

    The principal basis for seeking such relief is the marriage solemnized
    9 Bail App No. 78/2026 c/w
    CRM (M) No. 303/2026

    between the parties on 23.03.2026, which admittedly took place after

    the registration of the FIR and during the pendency of the

    investigation.

    14) It is an admitted position that, on the date of registration of the FIR, the

    victim had already attained the age of majority. Her date of birth, as

    recorded in the matriculation certificate, is 20.01.2008. It is equally

    well settled that, although the Protection of Children from Sexual

    Offences Act, 2012 does not prescribe any independent procedure for

    determination of the age of the victim, the age is required to be

    determined in accordance with the procedure contemplated under

    Section 94 of the Juvenile Justice (Care and Protection of Children)

    Act, 2015. The said provision provides the statutory mechanism for

    age determination and has consistently been applied by courts while

    adjudicating prosecutions under the POCSO Act (Section 34).

    15) The Hon’ble Apex Court, in Rajni v. State of Uttar Pradesh and

    Another, 2025 INSC 737, has categorically laid that the statute

    prescribes a clear hierarchy of documents for determination of age.

    The first and foremost document is the matriculation or equivalent

    school certificate reflecting the date of birth; in its absence, the birth

    certificate issued by the Municipal Corporation, Panchayat or other

    competent authority is to be relied upon; and only where both such

    documents are unavailable can recourse be taken to medical opinion or

    an ossification test.

    10 Bail App No. 78/2026 c/w

    CRM (M) No. 303/2026

    16) In the present case, the matriculation certificate relied upon by the

    petitioners records the victim’s date of birth as 20.01.2008. The

    material collected during investigation, as reflected in the case diary,

    further reveals that at the time the FIR came to be registered, the

    victim had delivered a female child through a normal vaginal delivery

    after completing approximately 36 weeks of gestation. These facts

    prima facie indicate that the conception had occurred when the victim

    was below 18 years of age. Therefore, there appears to be considerable

    substance in the submission advanced on behalf of the respondents that

    the subsequent marriage between the victim and petitioner No. 1 was

    solemnized only after the victim had undergone the trauma of an

    unwanted pregnancy allegedly resulting from the sexual assault, and

    that such marriage may have been entered into with the object of

    enabling petitioner No. 1 to evade the consequences of the criminal

    prosecution.

    17) While the victim has alleged that she was subjected to forcible sexual

    intercourse, she has simultaneously joined the accused in seeking

    quashing of the FIR. This apparent inconsistency reflects the

    predicament and emotional dilemma in which the victim appears to

    have found herself. Learned counsel for the petitioners, however,

    vehemently contended that the relationship between the parties was

    consensual throughout and that petitioner No. 1 had never resiled from

    his intention to marry the victim. It was further argued that the FIR

    was neither lodged by the victim nor by her parents and that the
    11 Bail App No. 78/2026 c/w
    CRM (M) No. 303/2026

    criminal proceedings came to be initiated only after the hospital

    authorities informed the police that an unmarried girl had delivered a

    child, thereby rendering the prosecution an afterthought. These rival

    submissions, however, can only be appreciated in the light of the

    material collected during investigation and are matters to be examined

    during the course of the trial.

    18) Be that as it may, the victim has made a statement under Section 183,

    which forms part of the investigation, alleging that petitioner No. 1

    subjected her to sexual assault during the period when she was a

    minor. Even assuming that the relationship was consensual, such

    consent is of no legal consequence, as the victim, being a minor at the

    relevant time, was incapable of giving valid consent in the eyes of law.

    The petitioners have sought to derive support from the decision in K.

    Kirubakaran v. State of Tamil Nadu, 2025 INSC 1272 to contend that

    petitioner No. 1 never intended to deceive the victim but had always

    intended to marry her. However, the reliance is misplaced. In that case,

    the accused had been convicted under Section 6 of the POCSO Act,

    and the conviction was affirmed by the Madras High Court.

    Subsequently, after the conviction and sentence had attained finality,

    the accused and the victim solemnized their marriage in the presence

    of their families, and the marriage resulted in the birth of a male child.

    In those peculiar facts and circumstances, the Hon’ble Supreme Court,

    invoking its extraordinary jurisdiction under Article 142 of the

    Constitution of India, proceeded to quash the criminal proceedings.
    12 Bail App No. 78/2026 c/w
    CRM (M) No. 303/2026

    The factual matrix of the said case is, therefore, entirely

    distinguishable from the present case.

    19) In the present matter, the investigation is still in progress. At this stage,

    the petitioners have failed to establish that the allegations of forcible

    sexual assault levelled by the victim (petitioner No. 2) are devoid of

    any legal or factual foundation. Learned counsel for the petitioners also

    placed reliance upon State of Uttar Pradesh v. Anurudh and Another,

    2026 INSC 47. However, the said judgment is equally inapplicable to

    the facts of the present case. The Hon’ble Supreme Court therein was

    primarily dealing with the legality of certain directions issued by the

    High Court, which were found to be contrary to the statutory scheme

    of the Juvenile Justice Act. While doing so, the Court observed that the

    misuse of the POCSO Act reflects a serious societal concern: on one

    hand, many child victims remain silenced by fear, poverty, or social

    stigma, rendering justice elusive; on the other hand, persons possessing

    social, educational, or financial privilege are, at times, able to

    manipulate the legal process to their advantage. The Court also noticed

    instances where the age of the victim is misrepresented to attract the

    stringent provisions of the POCSO Act, as well as cases where the

    statute is invoked by families to oppose consensual relationships

    between adolescents. It was in that context that the Hon’ble Supreme

    Court recommended that the Legislature consider incorporating a

    “Romeo and Juliet” clause in the statutory framework to exclude

    genuine adolescent relationships from the rigours of the Act.
    13 Bail App No. 78/2026 c/w
    CRM (M) No. 303/2026

    20) It shall be open to petitioner No. 1 to establish during the course of

    trial that the statement made by the victim under Section 183 was the

    result of police influence or a tainted investigation. However, as

    matters presently stand, petitioner No. 1 has failed to demonstrate that

    the investigation is vitiated by mala fides, ulterior motives, or any

    procedural illegality, or that the material collected during investigation

    does not disclose the commission of any cognizable offence.

    21) On the contrary, the victim has, in her statement recorded under

    Section 183, specifically levelled allegations against petitioner No. 1.

    The parents of the victim have also stated that the victim informed

    them that petitioner No. 1 had subjected her to forcible sexual

    intercourse without her consent, which ultimately resulted in her

    pregnancy. At the same time, it may pose a serious challenge for the

    prosecution during trial to explain how the victim’s parents remained

    unaware of their daughter’s pregnancy throughout its course,

    culminating in the delivery of a fully developed child.

    22) While exercising jurisdiction for quashing criminal proceedings, this

    Court cannot undertake an appreciation of evidence or adjudicate upon

    disputed questions of fact, as such an exercise squarely falls within the

    domain of the trial Court.

    23) In view of the foregoing discussion, this Court is of the considered

    opinion that no case for quashing the proceedings is made out.

    Accordingly, CRM (M) No. 303/2026 is dismissed. The

    investigating agency shall proceed with the investigation in
    14 Bail App No. 78/2026 c/w
    CRM (M) No. 303/2026

    accordance with law and file the final report/charge-sheet before

    the competent Court.

    24) While considering the present bail application, this Court, in the

    exercise of its jurisdiction to grant or refuse bail, is required to

    examine whether there exist a prima facie case or reasonable grounds

    for believing that the accused has committed the alleged offence. The

    Court is also required to take into account the nature and gravity of the

    accusation, the severity of the punishment in the event of conviction,

    and the likelihood of the accused absconding or fleeing from justice if

    released on bail. It is equally well settled that the mere apprehension of

    the accused tampering with the evidence or influencing witnesses

    cannot, by itself, constitute a sufficient ground for refusal of bail.

    However, where the material on record indicates that the accused is of

    such character or influence that his liberty is likely to intimidate

    witnesses, interfere with the administration of justice, or otherwise

    subvert the course of investigation or trial by tampering with evidence,

    the Court would be justified in declining the relief of bail.

    25) In this regard, reference may be made to the decision of State of U.P.

    v. Amarmani Tripathi (2005) 8 SCC 21. Similar principles were

    reiterated by the Hon’ble Supreme Court in Vaman Narain Ghiya v.

    State of Rajasthan, 2009 (2) SCC 281, wherein it was held as under:

    “While considering an application for bail, detailed discussion of the
    evidence and elaborate documentation of the merits is to be avoided. This
    requirement stems from the desirability that no party should have the
    impression that his case has been pre-judged. Existence of a prima facie case
    is only to be considered. Elaborate analysis or exhaustive exploration of the
    15 Bail App No. 78/2026 c/w
    CRM (M) No. 303/2026

    merits is not required. Where the offence is of serious nature the question of
    grant of bail has to be decided keeping in view the nature and seriousness of
    the offence, the character of the evidence and amongst others the larger
    interest of the public.”

    26) Learned counsel for the respondents has vehemently contended that the

    petitioner has neither joined the investigation nor cooperated with the

    investigating agency and has remained absconding since the

    registration of the FIR. The petitioner has, however, stoutly

    controverted the said allegation by submitting that he is serving in the

    Army and that the Investigating Officer had been duly informed of his

    continued service. It is argued that despite being aware of the

    petitioner’s place of service, the investigating agency made no sincere

    effort to secure his custody through the competent Army authorities. A

    perusal of the case diary lends support to this contention, as it reveals

    that, apart from issuing a communication to the Army authorities

    requesting the petitioner’s appearance, no further effective steps were

    taken to secure his presence. In these circumstances, the allegation that

    the petitioner was deliberately absconding cannot be accepted as an

    unquestionable fact.

    27) It is also noteworthy that while the FIR came to be registered on

    21.02.2026, the petitioner and the victim are stated to have solemnized

    their marriage on 23.03.2026 at Arya Samaj Janipur Colony, Jammu.

    According to the petitioners, the marriage was witnessed by members

    of both families. If this assertion is correct, it necessarily follows that

    the petitioner travelled from his place of posting to Jammu for the
    16 Bail App No. 78/2026 c/w
    CRM (M) No. 303/2026

    purpose of the marriage. Such conduct does not prima facie support the

    prosecution’s allegation that the petitioner had been evading the

    process of law or had intentionally absconded after registration of the

    FIR.

    28) The petitioner seeks the extraordinary relief of anticipatory bail on the

    plea that the criminal proceedings have been initiated with an oblique

    motive and that the prosecution is an abuse of the process of law. It is

    contended that neither the victim nor her parents lodged any complaint

    alleging sexual assault and that the FIR came to be registered only

    after the hospital authorities informed the police that the victim, being

    an unmarried minor, had delivered a child. It is further submitted that

    the consensual relationship between the petitioner and the victim was

    well known to their respective families and that immediately after the

    victim attained the age of majority in the year 2026, both parties

    solemnized their marriage, thereby demonstrating that the petitioner

    never intended to commit any offence.

    29) Learned counsel for the petitioner has further argued that the sole

    object of the investigating agency is to secure the petitioner’s arrest so

    as to subject him to humiliation and unnecessary harassment, which

    may also result in the loss of his employment in the Army. On the

    other hand, learned counsel appearing for the respondents has

    submitted that the victim and the child are presently under the care of

    the Child Welfare Committee and that collection of the petitioner’s

    DNA sample is imperative for establishing the paternity of the child,
    17 Bail App No. 78/2026 c/w
    CRM (M) No. 303/2026

    which constitutes an important piece of evidence in the investigation.

    The case diary also records that the investigating agency intends to

    obtain the petitioner’s DNA sample for this purpose.

    30) Having considered the rival submissions, it is evident that the

    petitioner’s consistent stand is that he was in a consensual relationship

    with the victim and that they solemnized their marriage after the

    registration of the FIR. In effect, the petitioner acknowledges that he

    had maintained a relationship with the victim during the period when

    she was a minor and that the said relationship culminated in her

    pregnancy and the subsequent birth of a female child. In view of this

    admission, there ought to be no hesitation on the part of the petitioner

    in submitting himself for DNA examination whenever lawfully

    required by the investigating agency.

    31) The principal question that now arises for consideration is whether, in

    the peculiar facts and circumstances of the case, the petitioner is

    entitled to the relief of anticipatory bail. Having regard to the material

    placed on record, this Court is of the considered view that the question

    deserves to be answered in the affirmative.

    32) According to the victim herself, the alleged incident occurred

    sometime in the month of June, 2025. It is not possible, at this stage, to

    conclusively determine whether the victim conceived as a consequence

    of a solitary act of sexual intercourse. Although she has stated that the

    petitioner had advised her to terminate the pregnancy, she refused to

    do so. It was only when she experienced labour pains that her parents
    18 Bail App No. 78/2026 c/w
    CRM (M) No. 303/2026

    took her to the hospital at Udhampur, where she disclosed that the

    petitioner had subjected her to sexual intercourse. Significantly,

    despite the obvious social repercussions attached to such allegations,

    neither the victim nor her parents approached the police to lodge a

    complaint. The criminal law was set in motion only after the hospital

    authorities informed the police that the victim, being an unmarried girl

    who had conceived while still a minor, had delivered a child.

    33) Learned counsel for the official respondents has fairly submitted that

    the marriage was merely a device adopted by the petitioner to create

    mitigating circumstances in his favour. Such a submission may indeed

    have relevance at the appropriate stage of the proceedings.

    Nevertheless, the admitted factual position remains that the victim was

    a minor at the time when the physical relationship developed and,

    therefore, in law, her consent would be of no consequence for the

    purpose of determining criminal liability under the POCSO Act. At the

    same time, the subsequent conduct of the parties, particularly their

    marriage after the victim attained majority, has neither been shown to

    have been brought about by coercion nor by any threat or undue

    influence. This aspect cannot be altogether ignored while considering

    the limited question of grant of bail.

    34) The petitioner has challenged the applicability of the provisions of the

    POCSO Act at the very first available opportunity, namely, during the

    consideration of his prayer for anticipatory bail. His contention is that

    although the victim was below eighteen years of age, she was more
    19 Bail App No. 78/2026 c/w
    CRM (M) No. 303/2026

    than seventeen years old, was fully conscious of her actions and had

    voluntarily participated in the relationship which ultimately resulted in

    her pregnancy.

    35) The petitioner has also been able to demonstrate certain inconsistencies

    in the conduct of the victim. While, on the one hand, she has made

    allegations against him in her statement under Section 183 of the

    Bharatiya Nagarik Suraksha Sanhita, on the other hand, after attaining

    majority, she voluntarily joined him in seeking quashing of the FIR.

    This apparent inconsistency lends some prima facie support to the

    petitioner’s apprehension that the provisions of the POCSO Act have

    been invoked in circumstances where the parties themselves assert that

    they were in a consensual relationship. Needless to observe, the prayer

    for bail under the POCSO Act is required to be considered strictly in

    accordance with the settled principles governing grant of bail. While

    the victim’s minority at the relevant time cannot be overlooked, her

    subsequent conduct and the inconsistencies in her version constitute

    circumstances that may legitimately be taken into account while

    considering the petitioner’s prayer for bail. The petitioner is serving in

    the Army, and there is nothing on record to indicate that he is likely to

    flee from justice or interfere with the investigation. The fundamental

    object of bail is to secure the presence of the accused during the course

    of the proceedings, and the investigation in the present case is still

    underway.

    20 Bail App No. 78/2026 c/w

    CRM (M) No. 303/2026

    36) For the foregoing reasons, this Court is satisfied that the petitioner has

    made out a strong prima facie case for grant of anticipatory bail.

    Accordingly, on being arrested, he shall be released from custody on

    his furnishing of bail and personal bond to the satisfaction of the

    Investigating Officer and on condition of his extending full

    cooperation with the investigation, enabling the later to conclude his

    investigation and in case charge is made out then proceed with filing of

    charge sheet against the petitioner. Once that stage is reached the trial

    court shall be free to impose further conditions for securing presence

    of the petitioner in trial. The bail application is, accordingly, disposed

    of.

    37) Copy of this order be furnished to the I/O for compliance.

    (Sanjay Parihar)
    Judge
    JAMMU
    24.06.2026
    Manik

    Whether this order is speaking : Yes
    Whether this order is reportable : Yes



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