The Supreme Court upheld the determination of an accused as a juvenile under the Juvenile Justice (Care and Protection of Children) Act, 2015, emphasizing that school records and birth certificates take precedence over medical age tests under Section 94(2). The Court clarified that once juvenility is established, bail considerations for juveniles differ from adults, focusing on rehabilitation rather than offence gravity. It also affirmed that Section 15 (preliminary assessment for heinous offences) does not negate juvenile status but mandates a separate evaluation for trial as an adult. The ruling reinforced the statutory hierarchy of age-proof documents and restricted JJBs from reviewing earlier age determinations.
Facts Of The Case:
The case involves Rajni (appellant), the mother of a deceased victim, challenging the declaration of Respondent No. 2 (Anmol alias Akki) as a juvenile in a murder case. The incident occurred on 17.02.2021, and Respondent No. 2 was accused under Sections 302/201/34 IPC and Arms Act provisions. Initially, the Juvenile Justice Board (JJB) dismissed his juvenility claim, relying on a medical report stating he was around 21 years old. However, the Additional Sessions Judge overturned this, accepting his school records (DPS Meerut) showing his birthdate as 08.09.2003, making him 17 years old at the time. The Allahabad High Court upheld this decision, emphasizing that documentary evidence (school certificates) prevails over medical opinion under Section 94 of the JJ Act, 2015.
Separately, Respondent No. 2 sought bail, which was initially denied by the JJB and Sessions Court, but the High Court granted it, observing that juveniles cannot be denied bail solely based on offence gravity. Rajni appealed to the Supreme Court, arguing that Respondent No. 2 was an adult with a criminal history and that bail was wrongly granted. The Supreme Court dismissed the appeal, affirming the primacy of school records in age determination and refusing to interfere with bail after three years of liberty. The Court clarified that Section 15 (preliminary assessment for heinous offences) applies but does not override juvenility if proven.
Procedural History:
The case originated with the Juvenile Justice Board (JJB), Meerut, dismissing Respondent No. 2’s plea for juvenility in Miscellaneous Case No. 55/2021, relying on a medical report that estimated his age at 21 years. Aggrieved, Respondent No. 2 appealed before the Additional District and Sessions Judge, Meerut, which reversed the JJB’s order in Criminal Appeal No. 67/2021, accepting his school certificate (showing DOB: 08.09.2003) as conclusive proof of juvenility under Section 94 of the JJ Act, 2015. The appellant, Rajni (victim’s mother), then filed Criminal Revision No. 82/2022 before the Allahabad High Court, which upheld the Sessions Court’s decision, reaffirming the supremacy of documentary evidence over medical opinion.
Concurrently, Respondent No. 2’s bail application was rejected by the JJB (27.10.2021) and the Sessions Court (01.12.2021). However, the High Court, in Criminal Revision No. 234/2022, granted him bail on 13.05.2022, observing that juveniles cannot be denied bail based solely on offence gravity. Rajni challenged both the juvenility declaration and bail order before the Supreme Court via SLP (Crl.) Nos. 11233/2022 & 7370/2022, which were converted into Criminal Appeal Nos. 603 & 2569 of 2025. The Supreme Court, in its judgment dated 20.05.2025, dismissed the appeals, upholding the High Court’s rulings on both juvenility and bail, while clarifying the legal hierarchy of age-proof documents under the JJ Act.
READ ALSO : Tender Scam Verdict: Supreme Court Explains Difference Between Forgery & Corruption in Govt Tenders
Court Observation:
The Supreme Court made several key observations while dismissing the appeal. It emphasized that school records and birth certificates hold primacy over medical age determination tests under Section 94(2) of the JJ Act, 2015, and courts cannot disregard such documentary evidence once verified. The Bench clarified that previous JJB orders declaring the accused’s age in earlier proceedings (Miscellaneous Case No. 9/2000) were binding, as the JJB lacks review powers under the Act.
On bail, the Court noted that juveniles cannot be denied bail merely because of offence gravity, as rehabilitation remains the Act’s focus. However, it affirmed that Section 15 mandates a preliminary assessment for heinous offences by juveniles aged 16-18 years, though this doesn’t negate their juvenile status. The Court declined to cancel bail after three years, observing no misuse of liberty, but left the door open for future cancellation proceedings if required. Importantly, it ruled that hypertechnical scrutiny of age-proof documents is impermissible, and borderline cases must lean in favor of juvenility to ensure the Act’s protective intent is fulfilled.
Final Decision & Judgement:
The Supreme Court, in its final judgment dated 20th May 2025, dismissed both criminal appeals (Nos. 603 & 2569 of 2025) and upheld the Allahabad High Court’s rulings on juvenility and bail. The Court reaffirmed that Respondent No. 2 (Anmol alias Akki) was correctly declared a juvenile based on his school records (DOB: 08.09.2003), which took precedence over conflicting medical reports under Section 94(2) of the JJ Act, 2015. It emphasized that documentary evidence like school certificates and birth records are conclusive proof of age when available, and JJBs cannot order medical tests unless such documents are absent.
Regarding bail, the Court refused to interfere with the High Court’s 2022 order granting bail, noting that three years had passed without misuse of liberty, and juveniles cannot be denied bail solely due to offence gravity. However, it clarified that the State or complainant could seek bail cancellation if future violations occur. The judgment reinforced the reformative purpose of the JJ Act, stressing that borderline age disputes must favor juvenility to protect children’s rights, while heinous offences by 16-18-year-olds still require Section 15 preliminary assessment for potential trial as adults. No costs were awarded. [Justice Ujjal Bhuyan & Justice Abhay S. Oka] concurred, upholding the primacy of statutory age-proof documents and the child-friendly approach of juvenile justice.
Case Details:
Case Title: Rajni vs. State of Uttar Pradesh & Anr. Citation:2025 INSC 737 Criminal Appeal No: Criminal Appeal No. 603 of 2025 (Arising out of SLP (Crl.) No. 11233 of 2022) Date of Judgment:20th May 2025 Judges/Justice Name: Justice Ujjal Bhuyan & Justice Abhay S. Oka
Download The Judgement Here