This Supreme Court judgment affirms that claims of juvenility under the Juvenile Justice Act, 2000 can be raised at any stage, even post-conviction. The Court held that a juvenile offender cannot be detained beyond the statutory maximum period prescribed under the Act, and such excess detention violates Article 21 of the Constitution.
Facts Of The Case:
The petitioner, born on 10th June 1969, was convicted for a murder allegedly committed on 2nd November 1981, when he was approximately 12 years and 5 months old. The trial court, in its 1984 order, recognized his juvenility under the Children Act, 1960 and directed his placement in a children’s home instead of prison. Following a reversal of his acquittal by the Supreme Court in 2009, the petitioner absconded and was subsequently arrested on 19th May 2022. He filed a writ petition seeking release, contending his continued detention was illegal as he was entitled to the benefits of the Juvenile Justice Act, 2000. He argued that as a juvenile at the time of the offence, the maximum permissible detention was three years, a period he had already exceeded. The State opposed, arguing the older 1960 Act applied and emphasized the gravity of the offence. The Supreme Court, focusing on the legal question of applicable juvenile law and the duration of detention, allowed the petition.
Procedural History:
The procedural history of this case commenced with the petitioner’s conviction and sentencing by the Sessions Court, Sultanpur, in 1984, which recognized his juvenility under the Children Act, 1960. His appeal, along with co-accused, resulted in acquittal by the Allahabad High Court in 2000. The State’s appeal to the Supreme Court succeeded in 2009, restoring the conviction. Following this, the petitioner absconded until his arrest in May 2022. He then invoked the Supreme Court’s writ jurisdiction under Article 32 of the Constitution, filing the present petition in 2025, seeking release on the grounds of being a juvenile entitled to the benefits of the Juvenile Justice Act, 2000, which limits detention to a maximum of three years.
READ ALSO:Supreme Court Allows Older Couples to Continue Surrogacy if Embryos Frozen Before 2022
Court Observation:
The Court observed that the petitioner was undisputedly a juvenile (approximately 12 years old) at the time of the offence in 1981. It held that the beneficial provisions of the Juvenile Justice Act, 2000, particularly Section 7-A, apply retrospectively. This allows a claim of juvenility to be raised at any stage, even after final disposal of a case. Since the petitioner had already been detained for over three years—exceeding the maximum period prescribed for juveniles under the Act—his continued incarceration was not in accordance with the procedure established by law. Consequently, the Court found a clear breach of his fundamental right to liberty under Article 21 of the Constitution.
Final Decision & Judgement:
The Supreme Court allowed the writ petition. It held that the petitioner, having been a juvenile at the time of the offence, was entitled to the benefits of the Juvenile Justice Act, 2000. As his detention of over three years exceeded the maximum period permissible for a juvenile offender, his continued incarceration was illegal and violated Article 21 of the Constitution. The Court directed his immediate release from custody.
Case Details:
Case Title: Hansraj v. State of U.P. Case Number: Writ Petition (Crl.) No. 340 of 2025 Date of Judgement: October 09, 2025 Judges/Justices Name: Justice Dipankar Datta and Justice Augustine George Masih