reasons”. What is an adequate and a special reason would depend upon a variety of factors and the peculiar facts and circumstances of each case. There exists no strait-jacket formula for universal application. In Ram Kumar Vs.State of Haryana reported as (2006) 4 SCC 347 wherein sufficient evidence was tendered by the prosecution to prove the guilt of the accused, the Apex Court, however, while considering the peculiar facts and circumstances of the case that the victim had got married and was living with her husband, had modified the sentence and reduced it to 3 years. In Ravindra Vs. State of Madya Pradesh report as (2015) 4 SCC 491 the Apex Court found it a fit case for invoking the proviso to Section 376; the incident being 20 years old, also the fact that the parties had since been married (not to each other) and that a compromise having been entered into were considered as “adequate and special reasons” under the proviso. In State Vs. Mange Ram AIR 2000 SC 2798 where the prosecutrix and the accused were related and both were teenagers and evidence indicating no marks of violence at all on any part of the body of the prosecutrix and also considering that the incident had happened in 1993, the Apex Court had held that the sentence of less than 7 years already undergone by the accused would be sufficient to meet the ends of justice.
