A) ABSTRACT / HEADNOTE

This case delves into the legal question of juvenility under Section 94 of the Juvenile Justice (Care and Protection of Children) Act, 2015 and examines whether juvenility can be claimed after final conviction. The applicant sought relief on the basis that he was a minor on the date of the offense (17.01.2002) and had already served over four years of imprisonment. The Court, relying on factual findings and the statutory framework, concluded that juvenility claims could be raised at any stage, including post-conviction. The applicant’s birth records demonstrated he was 17 years and 3 months old at the time of the crime. Consequently, the Court set aside the conviction and acquitted the applicant.

Keywords: Juvenility, Juvenile Justice Act, Post-conviction relief, Date of birth determination, Criminal procedure.

B) CASE DETAILS

i) Judgement Cause Title:
State of Madhya Pradesh v. Ramji Lal Sharma & Another

ii) Case Number:
Miscellaneous Application No. 261 of 2024 in Criminal Appeal No. 293 of 2022

iii) Judgement Date:
23 September 2024

iv) Court:
Supreme Court of India

v) Quorum:
Hon’ble B.V. Nagarathna and Nongmeikapam Kotiswar Singh, JJ.

vi) Author:
B.V. Nagarathna, J.

vii) Citation:
[2024] 10 S.C.R. 411

viii) Legal Provisions Involved:

• Section 94 of the Juvenile Justice (Care and Protection of Children) Act, 2015
• Sections 302, 307, 34 of the Indian Penal Code, 1860
• Section 3(2)(v) of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989

ix) Judgments overruled by the Case (if any):
None

x) Case is Related to which Law Subjects:
Criminal Law, Juvenile Justice, Sentencing

C) INTRODUCTION AND BACKGROUND OF JUDGEMENT

The case originates from a criminal proceeding involving charges of murder and associated crimes under Sections 302, 307, and 34 of the Indian Penal Code, 1860, and Section 3(2)(v) of the SC/ST Act, 1989. The accused were initially convicted by the Trial Court in 2006, acquitted by the High Court in 2018, and reconvicted by the Supreme Court in 2022. Subsequently, the applicant claimed juvenility at the time of the offense. This application challenged the settled principle of finality in criminal judgments, emphasizing the right to claim juvenility even post-conviction.

D) FACTS OF THE CASE

1. Incident: The crime occurred on 17.01.2002. Four individuals, including the applicant, were implicated in murder charges under Sections 302, 307, and 34 IPC, along with Section 3(2)(v) SC/ST Act.

2. Trial Court Proceedings: The Trial Court convicted the applicant and sentenced him to life imprisonment with a fine.

3. High Court Appeal: The High Court overturned the conviction in 2018, acquitting all accused.

4. Supreme Court Appeal: On further appeal by the State, the Supreme Court reinstated the Trial Court’s conviction in 2022.

5. Claim of Juvenility: The applicant later filed an application under Section 94 JJ Act citing his date of birth (04.10.1984) as evidence that he was 17 years and 3 months old on the date of the offense.

6. Judicial Inquiry: The Sessions Judge conducted a detailed inquiry to verify the claim, relying on school records, testimony, and official documents.

E) LEGAL ISSUES RAISED

i) Can a claim of juvenility under the Juvenile Justice Act, 2015, be raised post-conviction?
ii) Is the applicant’s date of birth substantiated to establish his juvenility at the time of the offense?

F) PETITIONER/APPELLANT’S ARGUMENTS

1. Finality of Judgments: The State argued that the applicant’s claim was belated and challenged the long delay in raising juvenility after multiple stages of litigation.

2. Discrepancies in Evidence: The prosecution pointed out inconsistencies in the applicant’s identity and records, arguing these undermined the juvenility claim.

3. Impact on Victim’s Rights: The State contended that accepting such claims post-conviction could set a problematic precedent affecting victims’ justice.

G) RESPONDENT’S ARGUMENTS

1. Statutory Entitlement: The applicant’s counsel cited Section 94 of the JJ Act and case law (Abuzar Hossain v. State of West Bengal (2012) 10 SCC 489) to assert juvenility claims could be raised at any stage.

2. Factual Verification: They emphasized that the Sessions Judge’s inquiry validated the applicant’s date of birth as 04.10.1984.

3. No Cross-examination: The defense highlighted that the State did not challenge the evidence or testimonies in the inquiry.

H) JUDGEMENT

a. Ratio Decidendi:
The Court held that claims of juvenility could be raised post-conviction, as per Section 94 JJ Act. The Sessions Judge’s inquiry and corroborative evidence confirmed the applicant’s juvenility.

b. Obiter Dicta:
The Court noted the importance of protecting juvenile offenders’ rights under the law, even in delayed claims.

c. Guidelines (if any):

• Juvenility can be determined at any stage of criminal proceedings.
• Documentary and oral evidence from relevant authorities must substantiate the claim.

I) CONCLUSION & COMMENTS

The case reinforces the progressive intent of juvenile justice laws to prioritize rehabilitation over punishment for minors. The Court balanced procedural finality with statutory protections, underscoring that justice includes fairness for juvenile offenders.

J) REFERENCES

a. Important Cases Referred:

1. Abuzar Hossain v. State of West Bengal (2012) 10 SCC 489
2. Pramila v. State of Chhattisgarh, Criminal Appeal No. 64/2012

b. Important Statutes Referred:

1. Juvenile Justice (Care and Protection of Children) Act, 2015, Section 94
2. Indian Penal Code, 1860, Sections 302, 307, 34
3. Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989, Section 3(2)(v)