SUPREME COURT UPHOLDS JUVENILITY AND BAIL IN A MURDER CASE
The Judgment in the case of Rajni vs. State of Uttar Pradesh &Anr., Criminal Appeal No. 603 of 2025 (Arising out of SLP (Crl.) No. 11233 of 2022), along with Criminal Appeal No. 2569 of 2025, was delivered by the Supreme Court of India, comprising Hon’ble Justice Abhay S. Oka and Justice Ujjal Bhuyan on 20th May 2025. This case primarily addresses the determination of juvenility under the Juvenile Justice (Care and Protection of Children) Act, 2015 and the grant of bail to a juvenile Accused of committing a heinous offence under Section 302 IPC.
FACTS OF THE CASE
The Appellant Rajni, who is the mother of the deceased, challenged two orders passed by the High Court of Judicature at Allahabad. The dispute arose from an incident dated 17.02.2021, for which Respondent No. 2 (the Accused) was charged under Sections 302/201/34 IPC and Sections 3/25/27 of the Arms Act. The Juvenile Justice Board (JJB)Meerutdismissed an application to declare the Accused as a juvenile, holding that he was over 18 years of age on the date of the incident. However, the Additional District and Sessions Judge reversed this finding based on a school certificate showing his date of birth as 08.09.2003, declaring him a juvenile. The High Court upheld this decision. Separately, after the JJB and Sessions Court denied bail, the High Court granted it, observing that there were no grounds to deny bail to a juvenile in this case. These two High Court decisions, one upholding the declaration of juvenility and another granting bail, were challenged before the Supreme Court by the complainant.
MAIN ISSUES
- Whether the High Court and the Additional Sessions Judge were correct in declaring Respondent No. 2 a juvenile based on documentary evidence
- Whether the grant of bail by the High Court to Respondent No. 2 was legally justified under the Juvenile Justice Act, 2015
CONTENTIONS BY BOTH PARTIES
Appellant (Rajni)
The Appellant contended that Respondent No. 2 misused the provisions of the Juvenile Justice Act to escape punishment for a heinous crime (murder under Section 302 IPC). It was argued that the JJB had rightly relied on a medical board’s report that estimated the Accused age as 21 years, and that the Sessions Court and High Court erred in ignoring this. She further argued that Section 15 of the JJ Act, 2015 required a preliminary assessment of the Accused mental and physical capacity due to the heinous nature of the offence and the Accused prior criminal history.
Respondent No. 2 (Accused)
The Accused contended that the correct procedure under Section 94 of the JJ Act was followed by both the Sessions Court and High Court, and the school certificate and municipal birth certificate established his age as under 18. It was further argued that once declared a juvenile, the grant of bail was to be guided by different parameters, and the High Court rightly granted bail, especially since the Accused had not misused liberty for over three years.
JUDGMENT BY THE SUPREME COURT
The Supreme Court upheld the decisions of the Sessions Court and the High Court, declaring Respondent No. 2 a juvenile on the date of the incident, based on valid documentary evidence, a school certificate and a municipal birth certificate in line with Section 94(2) of the Juvenile Justice Act, 2015. It held that the JJB had erred in relying on a medical test despite the availability of documentary proof. The Court emphasized that the JJB had no power to review its own earlier order that had already accepted the same date of birth in a prior proceeding. Regarding bail, the Court declined to interfere with noting that the Accused had been on bail for over three years without any misuse of liberty and left it open to the complainant or State to seek cancellation if misuse occurred. Both criminal appeals were dismissed.
Parichaya Reddy
Associate
The Indian Lawyer & Allied Services
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