Caste-nexus requirement and sentencing reasons control enhanced punishment; life imprisonment reduced where statutory basis was not made out.

Section 3(2)(v) of the Scheduled Castes and the Scheduled Tribes (Prevention of Atrocities) Act, 1989 applies only where the underlying offence is committed on the ground of the victim's caste status; absent evidence of that nexus, the provision cannot sustain the enhanced punishment. For rape of a girl below twelve years, Section 376(2)(f) of the Indian Penal Code, 1860 permits life imprisonment only for special and adequate reasons. As no such reasons were recorded apart from the erroneous reliance on the Atrocities Act, the sentence was reduced to ten years' rigorous imprisonment, while the compensation order was left undisturbed.

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Issues: (i) Whether Section 3(2)(v) of the Scheduled Castes and the Scheduled Tribes (Prevention of Atrocities) Act, 1989 applied on the facts; (ii) whether the sentence of life imprisonment could be sustained and whether the compensation award required interference.

Issue (i): Whether Section 3(2)(v) of the Scheduled Castes and the Scheduled Tribes (Prevention of Atrocities) Act, 1989 applied on the facts.

Analysis: The provision applies only when the offence under the Indian Penal Code is committed against the victim on the ground that she is a member of a Scheduled Caste or Scheduled Tribe. The record contained no evidence that the assault was committed for that reason. The statutory requirement of nexus with caste status was therefore not established.

Conclusion: Section 3(2)(v) of the Scheduled Castes and the Scheduled Tribes (Prevention of Atrocities) Act, 1989 was inapplicable and could not sustain the sentence of life imprisonment.

Issue (ii): Whether the sentence of life imprisonment could be sustained and whether the compensation award required interference.

Analysis: For rape of a girl below twelve years of age, Section 376(2)(f) of the Indian Penal Code, 1860 prescribes a minimum sentence of ten years, with life imprisonment permissible in appropriate cases for special and adequate reasons. The Court emphasized the gravity of sexual violence, the evidentiary value of the victim's testimony, and that corroboration is not a legal necessity. Since no special and adequate reasons were recorded to justify life imprisonment apart from the erroneous reliance on the Atrocities Act, the sentence had to be reduced. The compensation award was not open to challenge by the State in the appeal filed by the accused.

Conclusion: The sentence was reduced to ten years' rigorous imprisonment, while the compensation direction was maintained.

Final Conclusion: The appeal succeeded only to the limited extent of reduction of sentence, and in all other respects the conviction and compensation order were left undisturbed.

Ratio Decidendi: Section 3(2)(v) of the Scheduled Castes and the Scheduled Tribes (Prevention of Atrocities) Act, 1989 applies only where the underlying offence is committed on the ground of the victim's caste status, and life imprisonment for rape under Section 376(2)(f) of the Indian Penal Code, 1860 requires special and adequate reasons beyond the statutory minimum punishment.

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