The recent Supreme Court's necessitated postscript in State of Uttar Pradesh v. Anurudh, advocated for a "Romeo-Juliet" exception for genuine peer relationship. It was in response of the critical problem in India's Protection of Children from Sexual Offences (POCSO) Act. This is reflected by a 93.8% acquittal rate in cases categorized as "romantic". This suggests that the law often punishes adolescent “autonomy” rather than addressing actual victimization. However, there exists a critical psychological blindspot, which is the difficulty in distinguishing between “informed consent” and "manufactured consent". This may result from predatory grooming through peer-on-peer manipulation.

Grooming, or "sexual manipulation," involves the systematic use of trust-building to normalize harmful behavior and prohibit disclosure. In contrast to forced abuse, grooming exploits the adolescent's neurobiological architecture, specifically the developmental gap between a heightened socio-emotional reward system and an immature cognitive control system. As young adults often lack a unified understanding of grooming, they may not perceive manipulative befriending as abuse, which may normalize risky behaviors.

Importantly, current judicial proxies to reason compliance are often insufficient indicators of consent. As in cases, Groomers may purposefully engineer emotional dependency to ensure the victim appears as a willing participant. Therefore, legal reform must evolve beyond behavioral checklists to catch these psychological blindspot. By integrating a fifth psychological criterion suggested, in this piece, assessing relational formation against the validated Sexual Grooming Model, the law can distinguish between true adolescent intimacy and predatory manipulation.

Statutory Provision on Adolescent's Consent and Grooming Gap

An analysis of 7,064 POCSO court judgments across 4 states reveals a pattern regarding adolescent sexuality, where 24.3% (Number= 1,715) of these cases were expressly categorized as "romantic" relationships. Crucially, 93.8% of these cases resulted in acquittals. This high acquittal rate is predominantly driven by the fact that in 81.5% of instances, the minor complainant refused to testify against the accused. Demographically, the data indicates this is largely a peer-to-peer issue, with over 77% of the accused being under 25 years old. This data reveals that POCSO, in a fair proportion of romantic cases, reveals signs of being operationalized as a legal mechanism for third-party grievance rather than victim-centered protection. In this regard, the Supreme Court's recent intervention in State v. Anurudh marks a significant shift as to how Indian courts are beginning to address the tension between POCSO's statutory age of consent and the reality of consensual adolescent relationships. In that case, the Court formally directed transmission of its judgment to the Government of India, recommending legislative consideration of a Romeo-Juliet exemption for genuine peer relationships. To guide adjudication in the interim, the Court drew upon the four-pronged framework articulated in Satish alias Chand v. State of U.P.: (i) requiring courts to assess relational context, (ii)consider the minor's own statement, (iii) exercise judicial discretion, and (iv) avoid outcomes that invert the protective purpose of the statute.

However, analytically, these criteria are primarily behavioral and contextual assessment of the relationship dynamics. This gap is analytically significant. Referring to the Child protection research on adolescent decision-making, particularly the distinction between "informed consent," where assent is the product of cognitive and emotional maturity. In contrast, "manufactured consent," which is the product of sustained manipulative conditioning. A more robust and psychologically-informed adjudicatory framework would require courts to move beyond behavioral proxies and assess the relational power dynamics rather than behavioral proxies.

The Psychological Gap of Manufactured Consent and the Limits of Behavioral Assessment

As discussed above, Grooming is defined as the systematic use of manipulative and controlling techniques with a vulnerable subject, across interpersonal settings, to establish trust, normalize sexually harmful behavior, and prohibit disclosure. Crucially, its principal feature is that neither observers nor the victim may recognize that abuse has occurred because the endpoint is not overt force but manufactured compliance. Scholarly research, drawing on Finkelhor's foundational precondition model, identify the overcoming of the child's resistance as the defining function of grooming. This may not be achieved through coercion but through deliberate trust-building, isolation with socio-cultural setting, and progressive boundary erosion. The validated Sexual Grooming Model operationalizes this across five sequential stages: (i) victim selection, (ii) gaining access and isolating the victim, (iii) trust development, (iv) desensitization to sexual content and physical touch, (v) and post-abuse maintenance behaviors. Each stage is designed to produce exact compliance that the authorities may read as evidence of consent including affection, willingness or silence.

What makes this especially consequential in the adolescent context is that the minor's neurobiological architecture renders them structurally vulnerable to each of these stages in ways an adult is not. The Dual Systems Model of Brain Development of Steinberg (2008) establishes a fundamental developmental mismatch in the adolescent brain where the socio-emotional system, which governs reward-seeking, emotional intensity, and heightened sensitivity to peer relationships, is activated abruptly at puberty and peaks around age fifteen. While the cognitive control system which is responsible for self-regulation, impulse control, and resistance to social influence, matures gradually and remains incomplete until the mid-twenties. This temporal gap is not a behavioral tendency but a neurobiological condition. A peer groomer targeting an adolescent is not merely exploiting inexperience, however, are weaponizing their cognition at its most vulnerable developmental point. By utilizing deep emotional dependency through a socio-emotional system that is wired to experience peer intimacy as intensely rewarding, while the prefrontal mechanisms that would otherwise enable the minor to critically evaluate that relationship remain structurally underdeveloped.

The outcome is a “grooming dynamic” that complicate courtroom assessment in ways that purely behavioral frameworks are ill-equipped to address. A minor subjected to sustained manipulative conditioning may present before a court as a willing participant by offering affectionate messages as evidence, describing the relationship in romantic terms, and declining to testify against the accused. This is not because the relationship was genuinely consensual, but because grooming has conditioned that very presentation. Critically, research further highlights that alleged perpetrator frequently framed abusive relationships as consensual and romantic, and that victims internalized this framing, producing cultures of silence in which disclosure was suppressed by fear of disbelief or of losing the relationship. Similarly, factual consent has been systematically misrepresented in close-in-age cases, obscuring the line between genuine adolescent autonomy and grooming-induced compliance. In the Indian context, this observation offers a plausible explanation for the high acquittal rates and victim hostility documented in POCSO romantic-categorized cases. This is where the minor's courtroom behavior may itself be a product of the conditioning under scrutiny. The evaluation of such relationships on behavioral markers or victim testimony alone therefore risks converting manufactured consent into a legal finding of informed consent, making close-in-age exemption into a mechanism that may shields perpetrator.

Toward a Fifth Criterion

To resolve foundation question of grooming, particularly how the relationship was formed and whether the consent expressed within it was psychologically capable of being free, this piece proposes a fifth criterion to sit alongside the existing four. This includes a structured psychological assessment of whether the minor's expressed consent was informed and autonomous or bears indicators of having been manufactured through systematic relational influence. This criterion would be operationalized through the existing Section 39 POCSO expert witness mechanism for expert assistance in child victim cases, directed toward a specific evaluative task: assessing the relational formation of the relationship against the five stages of the validated Sexual Grooming Model, namely victim selection, isolation, trust development, desensitization, and post-abuse maintenance. This requires no new institutional architecture. It assigns an existing provision a precise question it has never previously been required to answer. The legislative necessity of such an assessment is not without comparative grounding. Even, the Canadian Criminal Code, under Section 150.1, already acknowledges its close-in-age exemption on the requirement that the accused not be in a relationship with the complainant that is exploitative, recognizing that age proximity alone.

Ultimately, the fifth criterion, therefore, may aid to distinguish between genuine adolescent autonomy and manufactured compliance is not a line that behavioral observation or an authorities' checklist can reliably draw. As, the current situation requires the law to not merely swing from blanket punishment to blanket protection. POCSO was enacted to protect children from sexual abuse and exploitation. The Romeo-Juliet exception, if introduced without the psychological safeguards of a fifth criterion, risks inadvertently protecting the very individuals who exploit them instead.

Author Annanya Singh is a 3^rdyear Law student at CHRIST (Deemed to be University), Bangalore & Aneesha Rana is a PhD scholar at Rajiv Gandhi National University of Law, Patiala. Views are Personal.