Supreme Court Acquits Juvenile Offender at Time of Offense

New Delhi, September 23, 2024

In a landmark judgment, the Supreme Court of India has acquitted an individual, citing juvenility at the time of the offense. This decision came after a detailed enquiry established the individual's age as 17 years and 3 months during the incident dated January 17, 2002.

Background

The case originates from an FIR filed on January 17, 2002, at Police Station AJK Bhind, Madhya Pradesh, under charges including Sections 302, 307, and 34 of the Indian Penal Code (IPC), along with Section 3(2)(v) of the SC/ST Act. The individual, alongside others, was initially convicted by the Special Judge, Bhind, and sentenced to life imprisonment on February 24, 2006.

Appeals and Acquittal

Following an appeal, the High Court of Madhya Pradesh acquitted the respondents on December 13, 2018. This acquittal was contested by the State, leading to the Supreme Court's reinstatement of the original convictions on March 9, 2022.

Claim of Juvenility

Subsequent to the conviction, an application was filed claiming juvenility at the time of the offense. The Supreme Court directed an enquiry to verify this claim, revealing discrepancies in the individual's date of birth records. The Sessions Court confirmed the date of birth as October 4, 1984, establishing the age as a juvenile during the offense.

Legal Points and Considerations

1. Juvenile Justice Act: The Juvenile Justice (Care and Protection of Children) Act, 2015, aims to provide care, protection, treatment, development, and rehabilitation of neglected or delinquent juveniles. Under Section 94 of this Act, the age of juvenility can be determined through matriculation certificates or equivalent documents.
2. Past Precedents: The Supreme Court has consistently upheld the right to claim juvenility at any stage of a criminal proceeding. In Abuzar Hossain vs. State of West Bengal, it was held that such claims could be made even post-conviction.
3. Document Discrepancies: Despite discrepancies in the individual's name and birthdate across various documents, the Supreme Court emphasized the consistency in the parentage details and the findings from the detailed enquiry.
4. Enquiry Process: The Sessions Court's enquiry involved the examination of multiple witnesses, including the individual, their mother, and the school’s headmaster. The Sessions Court's report, aligning with Section 94 of the Juvenile Justice Act, was pivotal in establishing the juvenile status.

Supreme Court's Decision

Based on the detailed enquiry and legal precedents, the Supreme Court set aside the individual's conviction, granting the benefit of juvenility. Consequently, the sentence was annulled, and the individual was acquitted.

Conclusion

This verdict underscores the judiciary's commitment to ensuring justice, especially considering the legal protections for juveniles. The acquittal serves as a significant reminder of the due process and the importance of accurate age determination in criminal cases.