Introduction

The Supreme Court of India, in a significant ruling delivered on 19 December 2025, has upheld the conviction of an accused in a child trafficking and commercial sexual exploitation case, reinforcing the legal principles governing the appreciation of evidence of minor victims. The bench, comprising Justice Manoj Misra and Justice Joymalya Bagchi, dismissed the criminal appeal and upheld the concurrent findings of the trial court and the Karnataka High Court. 

Facts and Procedural History
The case arose out of information received from NGO workers alleging that minor girls were being used for prostitution in a rented apartment in Peenya, Bengaluru. A police raid was conducted, leading to the rescue of a minor girl who was exploited for commercial sexual purposes. The appellant, along with his co-accused (his wife), was charged under multiple provisions of the Indian Penal Code (IPC) and the Immoral Traffic (Prevention) Act (ITPA), including Sections 366A, 372, 373, and 34 of the IPC read with Sections 3, 4, 5 and 6 of the ITPA. 
Both the trial court and the High Court had convicted the accused, and the Supreme Court was called upon by the defense to review these findings. 

Judicial Approach to Testimony of Minor Victims
A central feature of the Supreme Court’s judgment is its reaffirmation that the credible testimony of a minor victim can independently sustain a conviction, particularly in commercial sexual exploitation and trafficking cases. The Court emphasized that minor victims are not accomplices to the offence, but are injured witnesses whose evidence must be evaluated with sensitivity and realism. Traditional skepticism or reliance on rigid technicalities should not undermine trustworthy testimony, especially where minor inconsistencies do not materially affect the reliability of the account. 

Age Determination: School Records Over Ossification Test
The age of the victim was conclusively established at 16 years and 6 months on the date of the incident through her school certificate. The Court reaffirmed settled legal principles that school records are primary documentary evidence of age and prevail over medical opinion based on ossification or radiological tests when such records are available. In doing so, the Court reiterated the legal position laid down in Jarnail Singh v. State of Haryana, that ossification tests are not to be treated as conclusive in the face of reliable documentary proof. 

Search Validity and Compliance with ITPA
The appellant challenged the legality of the search conducted under Section 15(2) of the ITPA, claiming it was flawed due to the absence of a local respectable woman as a witness. The Supreme Court rejected this contention, holding that non-compliance with procedural formalities under Section 15(2) may amount to irregularity but does not automatically render the search illegal unless prejudice is shown. Independent witnesses from an NGO present during the search were found sufficient for compliance. 

Convictions Upheld Under IPC and ITPA
After considering the totality of evidence — including the minor victim’s testimony, corroborating witness accounts, documentary proof, recovered marked currency in a decoy operation, and physical evidence found at the scene — the Supreme Court held that all the ingredients of offences under IPC Sections 366A, 373 and ITPA Sections 3, 4, 5 and 6 were clearly established. The Court accordingly upheld the conviction and dismissed the appeal. 

Significance of the Judgment
This judgment marks a victim-centric development in Indian criminal jurisprudence, particularly in cases involving child trafficking and sexual exploitation. By prioritizing the substantive truth over technical objections, especially where minor victims are involved, the Court has set a reinforcing tone that the criminal justice system must protect the most vulnerable and not allow procedural loopholes to shield perpetrators.

Case Citation:-
K.P. Kirankumar @ Kiran v. State by Peenya Police, 2025 INSC 1473, Supreme Court of India
Decision dated: 19 December 2025
Bench: Justice Manoj Misra and Justice Joymalya Bagchi
Statutes Involved:
IPC Section 366A, 373
Immoral Traffic (Prevention) Act, 1956 Section 3, 4, 5, 6