Appreciation of Testimonial Evidence of Minor Victims

The Supreme Court held that in cases of child trafficking and commercial sexual exploitation, the evidence of minor victims must be appreciated with sensitivity and realism. It held that the credible testimony of a minor victim can, by itself, sustain a conviction and cannot be rejected on the basis of minor inconsistencies.

K.P. Kirankumar and another accused were prosecuted for offences relating to procuration, buying and selling of a minor for prostitution and commercial sexual exploitation under Sections 366A, 372, 373 and 34 of the Indian Penal Code, 1860; read with Sections 3, 4, 5 and 6 of the Immoral Traffic (Prevention) Act, 1956. A minor girl was rescued after a police raid based on information provided by NGO workers. The Trial Court convicted the accused, and the Karnataka High Court dismissed their appeal, holding that the testimony of the minor victim was reliable and sufficiently corroborated.

The Supreme Court upheld the conviction and held that a minor victim of sex trafficking is not an accomplice and her testimony, if found credible and convincing, can form the basis of conviction as that of an injured witness.  Finding the victim’s age established by school records and her testimony consistent on material particulars, the appeal was dismissed.

K.P. Kirankumar v State
19 December 2025

Citations: 2025 INSC 1473 | 2025 SCO.LR 12(4)[20]

Read the Judgement here. https://www.scobserver.in/supreme-court-observer-law-reports-scolr/k-p-kirankumar-v-state-appreciation-of-testimonial-evidence-of-minor-victims/

Case comment:

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#legalcousel #legalawareness #legaladvice #childtrafficking #commercialsexualexploitation #victimtestimony

Keywords/phrases: child trafficking–commercial sexual exploitation–minor victim testimony–judicial appreciation of evidence–sensitivity and realism–victim not an accomplice–sole testimony sufficient for conviction–Sections 366A, 372, 373 IPC–Immoral Traffic (Prevention) Act, 1956–Sections 3, 4, 5 and 6–Karnataka High Court judgment affirmed–appeal dismissed

Bench: Justices Manoj Misra and Joymalya Bagchi

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