A) ABSTRACT / HEADNOTE

The Supreme Court deliberated on the plea of juvenility raised by Rahul Kumar Yadav in the context of his conviction for offenses under Sections 302 and 394 IPC and Section 27(2) of the Arms Act, 1959. The case revolved around the principle that the plea of juvenility could be invoked at any stage, even post-conviction or after final disposal of the matter, as per the Juvenile Justice (Care and Protection of Children) Act, 2015. The appellant contested that he was a juvenile at the time of the crime but claimed the courts below failed to adequately consider his plea. The Supreme Court underscored the importance of the reformation and rehabilitation focus of the Juvenile Justice Act and directed an inquiry into the appellant’s age to ensure procedural compliance and justice.

Keywords: Plea of juvenility, Juvenile Justice Act, Section 9(2), Procedural compliance, Age determination.

B) CASE DETAILS

i) Judgement Cause Title: Rahul Kumar Yadav v. The State of Bihar
ii) Case Number: Criminal Appeal No. 177 of 2018
iii) Judgement Date: April 25, 2024
iv) Court: Supreme Court of India
v) Quorum: B.R. Gavai and Sandeep Mehta JJ.
vi) Author: Justice Sandeep Mehta
vii) Citation: [2024] 5 S.C.R. 501 : 2024 INSC 359
viii) Legal Provisions Involved: Sections 302 and 394 IPC, Section 27(2) of the Arms Act, 1959, Section 9(2), 94 of Juvenile Justice Act, 2015, Section 7-A of Juvenile Justice Act, 2000, and Section 366 of CrPC.
ix) Judgments Overruled by the Case: None specified.
x) Case is Related to: Criminal Law, Juvenile Justice Act compliance, Sentencing law, Human Rights Law.

C) INTRODUCTION AND BACKGROUND OF JUDGMENT

The appellant, Rahul Kumar Yadav, was convicted by the trial court for offenses under Sections 302 and 394 IPC and sentenced to death. On appeal, the High Court commuted the death penalty to life imprisonment. Throughout the trial and appeal, Yadav asserted that he was a juvenile on the date of the offense, but the courts rejected his plea. The appellant’s claim was rooted in the provisions of the Juvenile Justice Act, 2015, which allow for the invocation of juvenility even at advanced litigation stages. The Supreme Court reviewed procedural compliance and emphasized the Act’s rehabilitative objectives, ordering an inquiry into the appellant’s age.

D) FACTS OF THE CASE

1. The appellant and a co-accused were convicted of murdering the victim during a robbery on July 27, 2011.
2. Both individuals were tried and sentenced to death by the First Additional Sessions Judge, Darbhanga.
3. Appeals were filed before the Patna High Court, which, through a split bench, upheld the conviction but commuted the sentence to life imprisonment.
4. A plea of juvenility was initially raised before the Chief Judicial Magistrate, citing the appellant’s horoscope, which was dismissed. The trial court similarly rejected subsequent pleas, despite evidence like a birth certificate being presented.
5. The appellant argued that procedural lapses violated his rights under the Juvenile Justice Act, leading to an unjust trial.

E) LEGAL ISSUES RAISED

1. Can the plea of juvenility be raised at an appellate or post-conviction stage?
2. What constitutes proper evidence for determining juvenility under the Juvenile Justice Act, 2015?
3. Did the trial court and the High Court comply with procedural mandates for assessing the claim of juvenility?
4. What is the role of ossification tests in the absence of documentary evidence of age?

F) PETITIONER/APPELLANT’S ARGUMENTS

1. Appellant was a juvenile at the time of the offense: The plea was improperly dismissed by the courts without thorough inquiry.
2. Documentary evidence ignored: A birth certificate presented before the trial court substantiated the claim but was summarily rejected.
3. Violation of Juvenile Justice Act mandates: The JJ Act, 2015 emphasizes reformation over punishment, rendering the adult criminal justice process inapplicable.
4. Reliance on judicial precedents: The appellant invoked Abuzar Hossain v. State of West Bengal [(2012) 10 SCC 489], which clarified the broad scope of raising a juvenility plea.

G) RESPONDENT’S ARGUMENTS

1. Belated plea of juvenility: The State argued that the appellant’s claim lacked credibility, as it was raised belatedly and inconsistently.
2. Horoscope evidence insufficient: The Chief Judicial Magistrate dismissed the horoscope-based claim, a stance supported by the trial and High Courts.
3. No procedural lapses: The State emphasized that courts appropriately weighed all evidence and arguments, rejecting juvenility claims based on insufficiency.

H) JUDGMENT

a. Ratio Decidendi

1. The JJ Act, 2015, permits juvenility claims at any litigation stage, emphasizing reformation and procedural compliance.
2. Courts must evaluate documentary evidence and, where absent, consider ossification tests to determine age.

b. Obiter Dicta
The judiciary should ensure procedural fairness to avoid hyper-technical dismissals of juvenility claims, safeguarding child rights under the JJ Act.

c. Guidelines
The Court directed:

1. Conducting an inquiry into the appellant’s age within 12 weeks.
2. Utilizing ossification tests if documentary evidence proves inconclusive.
3. Ensuring active cooperation from law enforcement in the collection of age-related evidence.

I) REFERENCES

1. Important Cases Referred
   • Abuzar Hossain v. State of West Bengal, [(2012) 10 SCC 489]
   • Vinod Katara v. State of Uttar Pradesh, [2022 SCC OnLine SC 1204]
2. Important Statutes Referred
   • Indian Penal Code, 1860
   • Juvenile Justice (Care and Protection of Children) Act, 2015
   • Code of Criminal Procedure, 1973