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Ravindra Narete vs. State of Maharashtra – 2025


Author: Naina Singh, Amity Law School, Punjab


CASE OVERVIEW

  • CITATION: Ravindra s/o Laxman Narete v. State of Maharashtra (2025)

  • COURT: Bombay High Court, Nagpur Bench

  • YEAR: decided 30th June 2025

  • BENCH: Justice Urmila Joshi-Phalke of the Bombay High Court, Nagpur Bench.

  • APPEAL: The accused challenged the conviction and sentence


INTRODUCTION

‘Ravindra Narete vs. State of Maharashtra (2025): the case represents a milestone ruling of the Bombay High Court in which it made it crystal clear that merely voicing “I love you” does not constitute erotic intention and hence the speaker (here, accused)  should not be convicted with the offences of ‘Sexual Harassment’ (under section 354-A IPC); ‘Stalking’ (under section 354-D IPC) or section 8 of the POCSO Act,2012 which is ‘Aggravated sexual assault' on a child/dependent by a person in a position of trust or responsibility, which were the key legal issues in this specific case.


FACTS OF THE CASE

PARTIES INVOLVED:

  • “Ravindra Narete s/o Laxman Narete” was the Appellant in the Bombay High Court and, the Accused, Defendant in the Trial Court who convicted him for offences under Sections 354-A(i), 354-D(1)(i) of the Indian Penal Code, and Section 8 of the POCSO Act.


  • “State of Maharashtra” was the Respondent, Plaintiff represented by the prosecution and police authorities. The State was the respondent in the criminal appeal, defending the conviction and sentence passed by the Trial Court.

    A “minor female” was the victim in this case.


RELEVANT FACTS:

  • A minor girl (the victim), aged 17 years, resident of Khapa, Tehsil Katol, district Nagpur studying in the 11th Std. Umri was returning home by 1:00 pm along with her cousin on foot on 23.10.2015.

  • The accused, also from the same village known as “Balya”, at about 1:15pm, on motorcycle came towards the victim, held her hands and said and expressed that unless and until she discloses her name, he will not let her to go and declared that “I love you”,

  • Somehow the girl managed to free from his clutches and flee from that scene and urgently rushed home where she narrated the whole incident to her father, who on apprehension of the same filed a police report on 23.10.2015. 

  • Based on the said report, the police registered the crime under Section 354-A(i) and 354-D(1)(i) of the IPC and under Section 8 of the POCSO Act.

  • After due investigation, visit to the crime scene by the investigating officers, taking statements of witnesses a chargesheet was submitted to the trial court.

  • After hearing both the sides and considering the evidence on record, the learned Judge of the trial court held the accused guilty and sentenced him to undergo rigorous imprisonment for 3 years and to pay a fine Rs.5,000/-, in default, to undergo simple imprisonment for two months.

  •  Being aggrieved and dissatisfied with the same, the present appeal was preferred by the accused before the Bombay High Court.


COURT’S DECISION

The appeal was allowed; the previous judgement was quashed and set aside acquitting the accused of the offences for which he was charged and convicted.

GROUNDS FOR DOING SO includes-

  1. Learned counsel for the accused submitted that due to previous enmity, the accused is implicated in the alleged offence. The age of the victim is not proved. Though the alleged incident has occurred during daytime, no independent witness is examined by the prosecution.

  2. To attract the offence under Section 354-A of the IPC, the prosecution must establish that there was a physical contact by the accused with a “sexual intent” or a “demand” or a “request” for sexual favour or “making sexual coloured remarks”, which are absent in the present case.

  3. The charge under Section 354-D of the IPC is also not established as there is no evidence to show that the victim was followed by the accused to force personal interaction repeatedly despite a clear indication of disinterest by such a woman.

  4. It was also submitted that applicability of Section 8 of the POCSO Act, is also doubtful as Section 7 defines “sexual assault” means, “whoever, with sexual intent touches the vagina, penis, anus or breast of the child or makes the child touch the vagina, penis, anus or breast of such person or any other person, or does any other act with sexual intent which involves physical contact without penetration is said to commit sexual assault”, which were absent in the present crime. Even, the offence under section 8 of the POCSO Act, is not made out as there is no allegation that either the accused with “sexual intent” touches private part of the victim described under Section 7 of the POCSO Act involving physical contact and, therefore, the offence under Section 8 is also not made out.

  5. A bare perusal of the evidence of prosecution witnesses nowhere reveals that with a “sexual intent”, these words, “I Love You”, are used by the accused, There should be something more which must suggest that the real intention is to drag in the angle of sex, if the words uttered are to be taken as conveying sexual intent. It should be reflected by the act. On considering the evidence of the prosecution, to ascertain the state of mind of the accused, there is not a single circumstance indicating that the accused’s real intention was to establish sexual contact with the victim. There is no evidence on record showing that there was any gesture in the nature of “eye expression” or body language of the accused. Moreover, “utterances” in question have not been made repeatedly, but it was made only once. Such being the nature of evidence, “utterances” by the accused addressing the victim and heard by prosecution witness her cousin are not sufficient to indicate any “sexual intent” on part of the accused.

  6. The “sexual assault” without penetration has not been proved by the prosecution beyond reasonable doubt.


IMPACT OF THE CASE

The case highlights how expressions like “I love you” made toward a minor, when paired with non-consensual physical contact, are not harmless or romantic gestures—they are legally and morally punishable offenses raising awareness among youth, parents and teachers about the consequences of such behaviour. This case reinforces that consent and age are central to defining acceptable conduct, even in rural or informal settings.


ANALYSIS 

This is a relevant case to understand the importance of strict interpretation of the penal statutes like IPC and POCSO Act as the meanings of the acts should not be stretched liberally beyond their assigned meaning which happened under this case leading to the unjust conviction of the accused. The essential ingredients of a crime/offense when mentioned clearly should be strictly adhered to. The Court treated the minor victim’s statement as credible and sufficient, despite the absence of independent witnesses which should not be the case as the judgement should be unbiased and fair, more corroboration should be required.  While protective intent is commendable, expansion into single incidents for stalking and harassment raises concerns about:

  • Certainty of law.

  • Potential misuse by minors/police.

  • This case has set a critical example on how our judicial system takes such instances seriously to safeguard minors, punishing even single instances against minors. Adopting a progressive, victim-first approach in interpreting harassment and child protection laws.


CONCLUSION

At last, the Bombay High Court’s decision in Ravindra Narete v. State of Maharashtra exemplifies the judiciary’s disciplined approach differentiating the line between sexual intent  and mere confession of love, ensuring fairness in light of what amounts to “sexual harassment”. Mere confession of “I love you” without making any sexually coloured remark should not cause a person jail time as it is against his right to freedom of expression and speech under Article 19 of the Constitution. This case reinforces that intent matters and legal outcomes must reflect both personal moral responsibility and societal justice.


REFERENCES




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