Juvenility Claim in Murder Case: Supreme Court Orders Inquiry in Rahul Kumar Yadav vs. State of Bihar (2024)

Date of the Judgment: April 25, 2024

Citation: 2024 INSC 359

Judges: Hon’ble Mr. Justice B.R. Gavai and Hon’ble Mr. Justice Sandeep Mehta

Can a person convicted of a serious crime raise a claim of being a juvenile at any stage of the legal process, even after their conviction? The Supreme Court of India recently addressed this critical question in a case involving a murder conviction, emphasizing the importance of proper inquiry into claims of juvenility. The court’s decision highlights the protective provisions of the Juvenile Justice Act and ensures that individuals who were minors at the time of an offense are not treated as adults in the criminal justice system. This judgment clarifies the procedure for determining juvenility claims, even when raised belatedly. The bench comprised of Hon’ble Mr. Justice B.R. Gavai and Hon’ble Mr. Justice Sandeep Mehta.

Case Background

Rahul Kumar Yadav (the appellant) was convicted by the first Additional Sessions Judge, Darbhanga, for offenses under Section 302 (murder) and Section 394 of the Indian Penal Code, 1860, and Section 27(2) of the Arms Act, 1959. He was initially sentenced to death. The appellant claimed that he was a juvenile at the time of the incident, which occurred on July 27, 2011. This claim was initially rejected by the Chief Judicial Magistrate and later by the trial court. The Patna High Court also did not address the juvenility claim in its split judgment, which was later referred to a third judge who commuted the death sentence to life imprisonment.

Timeline:

Course of Proceedings

The appellant was convicted by the trial court and sentenced to death. The Patna High Court’s division bench had a split decision, leading to a referral to a third judge, who upheld the conviction but commuted the death sentence to life imprisonment. The appellant had raised the issue of juvenility before the Chief Judicial Magistrate and the trial court, but these claims were rejected. The High Court also failed to consider the juvenility claim. The Supreme Court noted that the High Court did not consider the juvenility claim despite the Juvenile Justice (Care and Protection) Act, 2015, coming into force, which allows for such claims to be raised at any stage.

Legal Framework

The Supreme Court considered the following legal provisions:

• Section 302 of the Indian Penal Code, 1860: This section defines the punishment for murder.
• Section 394 of the Indian Penal Code, 1860: This section defines the punishment for voluntarily causing hurt in committing robbery.
• Section 27(2) of the Arms Act, 1959: This section deals with the punishment for using prohibited arms.
• Section 7-A of the Juvenile Justice (Care and Protection of Children) Act, 2000: This provision allows a person to claim juvenility before any court.
• Section 9(2) of the Juvenile Justice (Care and Protection) Act, 2015: This section states that a plea of juvenility can be raised at any stage, even after the final disposal of the case. The proviso to this section clearly states that such a plea can be raised before any court and it shall be recognized at any stage, even after final disposal of the case.

The court emphasized that the Juvenile Justice Act, 2015, provides a comprehensive mechanism to consider claims of juvenility, and such claims should be addressed even if raised belatedly.

Arguments

Appellant’s Arguments:

• The appellant argued that his plea of juvenility was dismissed in a perfunctory manner by the trial court, without conducting a proper inquiry.
• He contended that the High Court also failed to address his claim of being a juvenile on the date of the incident.
• The appellant relied on the provisions of the Juvenile Justice Act, 2015, which allows for a plea of juvenility to be raised at any stage, even after the final disposal of the case.
• The appellant submitted that the trial court rejected his plea of juvenility simply on the ground that the same prayer had been turned down by the learned Chief Judicial Magistrate earlier.

State’s Arguments:

• The State argued that the plea of juvenility was raised belatedly and should not be entertained by the Supreme Court.

Submissions Table

Issues Framed by the Supreme Court

The Supreme Court did not explicitly frame issues in this order. However, the core issue before the court was:

1. Whether the appellant’s claim of juvenility should be considered despite being raised at a belated stage and after the High Court had passed its judgment.

Treatment of the Issue by the Court

The following table demonstrates as to how the Court decided the issues

Authorities

The Supreme Court relied on the following authorities:

• Abuzar Hossain vs State of West Bengal [(2012) 10 SCC 489]: The Supreme Court laid down guidelines for evaluating claims of juvenility raised for the first time before the Supreme Court. The court held that a claim of juvenility may be raised at any stage, even after the final disposal of the case. The court also laid down the kind of material which can be considered for the purpose of determining the juvenility.
• Vinod Katara v. State of Uttar Pradesh [2022 SccOnLine SC 1204]: The Supreme Court directed an inquiry regarding the age of the accused even though he had crossed 50 years of age, emphasizing the importance of considering juvenility claims at any stage.

Authorities Considered by the Court

Judgment

How each submission made by the Parties was treated by the Court?

How each authority was viewed by the Court?

✓ The Supreme Court followed the guidelines laid down in Abuzar Hossain vs State of West Bengal [(2012) 10 SCC 489]* which held that a claim of juvenility may be raised at any stage, even after the final disposal of the case.

✓ The Supreme Court also followed the precedent set in Vinod Katara v. State of Uttar Pradesh [2022 SccOnLine SC 1204]* where it was held that an inquiry regarding the age of the accused can be directed even at a belated stage.

What weighed in the mind of the Court?

The Supreme Court emphasized the importance of the Juvenile Justice Act and the need to ensure that the benefits of the Act are extended to those who are entitled to them. The court noted that the plea of juvenility was raised at the earliest opportunity before the Chief Judicial Magistrate and that the trial court rejected it without conducting a proper inquiry. The court was also influenced by the fact that the High Court did not consider the plea of juvenility despite the JJ Act, 2015, coming into force. The Court reiterated the principle that the plea of juvenility can be raised at any stage of the proceedings.

Fact:Law Ratio Analysis: The court’s decision was primarily driven by legal considerations (70%), specifically the provisions of the Juvenile Justice Act, 2015, and the precedents set by the Supreme Court in similar cases. The factual aspects (30%) of the case, such as the timing of the juvenility claim and the actions of the lower courts, also played a role in the court’s decision.

The Supreme Court’s reasoning was based on the following:

• The Juvenile Justice Act, 2015, allows a plea of juvenility to be raised at any stage, even after the final disposal of the case.
• The lower courts failed to conduct a proper inquiry into the appellant’s claim of juvenility.
• The Supreme Court has previously held that claims of juvenility should be considered even if raised at a belated stage.

The court did not consider any alternative interpretations, as the legal position was clear and supported by precedents and the provisions of the JJ Act, 2015.

The court’s decision was to direct a fresh inquiry into the appellant’s age, ensuring that the appellant’s claim of juvenility is properly addressed.

The court quoted the following from the judgment:

“The proviso to Section 9(2) of the JJ Act, 2015 clearly enumerates that plea of juvenility may be raised before any Court and it shall be recognised at any stage, even after final disposal of the case.”

“There are catena of decisions of this Court which hold that the plea of juvenility, even if not taken before the trial Court or the High Court, can be raised before this Court.”

“On going through the record, we find that proper inquiry in accordance with the provisions of the JJ Act, 2000 or the JJ Act, 2015 was not carried out so to consider the prayer made by the appellant to be treated as juvenile on the date of the incident even though the plea was raised at the earliest opportunity.”

There was no minority opinion in this case.

The Supreme Court’s decision is a reinforcement of the principle that the benefits of the Juvenile Justice Act must be extended to those who are entitled to them. The decision also underscores the importance of conducting proper inquiries into claims of juvenility, even when raised belatedly. This judgment will likely impact future cases by ensuring that lower courts take such claims seriously and follow the prescribed procedures.

Key Takeaways

• A claim of juvenility can be raised at any stage of legal proceedings, even after the final disposal of the case.
• Courts must conduct a proper inquiry into claims of juvenility, as per the Juvenile Justice Act, 2015.
• The Juvenile Justice Act, 2015, aims to protect the rights of children in conflict with the law, and its provisions should be interpreted liberally.
• The Supreme Court’s decision emphasizes the importance of ensuring that individuals who were minors at the time of an offense are not treated as adults in the criminal justice system.

Directions

The Supreme Court directed the first Additional Sessions Judge, Darbhanga, to conduct a thorough inquiry to determine the age/date of birth of the appellant in accordance with the procedure provided under the JJ Act, 2015, and the rules framed thereunder. The Station House Officer of the concerned police station was directed to provide full assistance in the collection of documents/evidence. The inquiry is to be completed within 12 weeks, and a report is to be submitted to the Supreme Court.

Development of Law

The ratio decidendi of this case is that a plea of juvenility can be raised at any stage of the proceedings, even after the final disposal of the case, and the courts are bound to conduct an inquiry into such claims. This judgment reinforces the existing legal position under the Juvenile Justice Act, 2015, and the guidelines laid down in previous Supreme Court judgments.

Conclusion

The Supreme Court’s decision in Rahul Kumar Yadav vs. The State of Bihar underscores the importance of considering claims of juvenility at any stage of legal proceedings. The court directed a fresh inquiry into the appellant’s age, ensuring that the provisions of the Juvenile Justice Act, 2015, are upheld. This judgment reaffirms the principle that the benefits of the Act must be extended to those who are entitled to them, even if the claim is raised belatedly.

Category

Parent Category: Juvenile Justice Act, 2015

Child Category: Section 9(2), Juvenile Justice Act, 2015

Parent Category: Criminal Law

Child Category: Murder

Parent Category: Indian Penal Code, 1860

Child Category: Section 302, Indian Penal Code, 1860

Child Category: Section 394, Indian Penal Code, 1860

Parent Category: Arms Act, 1959

Child Category: Section 27(2), Arms Act, 1959

FAQ

Q: Can a person claim to be a juvenile even after being convicted of a crime?

A: Yes, according to the Supreme Court, a claim of juvenility can be raised at any stage of the legal proceedings, even after the final disposal of the case.

Q: What should a court do when a claim of juvenility is raised?

A: The court is required to conduct a proper inquiry to determine the age of the person making the claim, following the procedures laid down in the Juvenile Justice Act, 2015.

Q: What if the claim of juvenility is raised very late in the proceedings?

A: Even if the claim is raised at a belated stage, the court is still obligated to consider it and conduct an inquiry, as the Juvenile Justice Act, 2015, allows for such claims to be raised at any stage.

Q: What is the significance of this Supreme Court judgment?

A: This judgment reinforces the principle that the benefits of the Juvenile Justice Act must be extended to those who are entitled to them. It also emphasizes the importance of conducting proper inquiries into claims of juvenility to ensure that minors are not treated as adults in the criminal justice system.