Suresh Nayak v. State of Karnataka
Karnataka High Court2026 SCC OnLine Kar 621Bench: J. S. Sunil Dutt Yadav
The Karnataka High Court upheld the conviction and dismissed the appeal. The Court held that the legal position on delayed FIR in sexual offences — particularly child sexual abuse — is settled by the Supreme Court in Ganesan v. State (2020) 10 SCC 573: delay in FIR by a child victim must be assessed in the sociological and psychological context of child sexual abuse, not by the standards of an adult stranger-violence scenario. The Court identified legally adequate explanations for delay: (i) threats by the accused against the victim or her family, (ii) emotional dependence of the victim on the accused in intra-family abuse, (iii) social stigma and fear of family reaction, and (iv) the child's incomplete understanding of the abuse until she was able to speak to a trusted adult or teacher. All four factors were present. The 8-month delay was held fully explained. Medical evidence of old healed injuries corroborated the victim's account of repeated abuse.