Supreme Court Upholds Juvenility Claim, Sets Aside Conviction in Landmark Case.


23 September 2024 Acquittal >> Criminal Law   |   Criminal Appeals & Suspension of Sentence >> Criminal Law   |   Criminal Trial >> Criminal Law   |   FIR >> Criminal Law  

In a pivotal ruling of State of Madhya Pradesh v/s Ramji Lal Sharma & Another, a court has granted relief to Brijnandan, also known as Brajesh Sharma, by acknowledging his juvenility at the time of an alleged crime in 2002. This decision comes in the context of his application for release from a jail sentence stemming from serious charges, including murder. The case traces back to January 17, 2002, when a crime was reported under FIR No. 8/2002 at the AJK Bhind police station in Madhya Pradesh. Brijnandan and three others were charged with offenses under Sections 302 (murder), 307 (attempted murder), and 34 (common intention) of the Indian Penal Code, as well as under the Scheduled Castes and the Scheduled Tribes (Prevention of Atrocities) Act, 1989. Following a trial, the accused were convicted in 2006, receiving life sentences and a fine.

However, in a significant turn of events, the Madhya Pradesh High Court acquitted the defendants in 2018, leading to the State’s appeal before the Supreme Court. The apex court restored the conviction in 2022, prompting Brijnandan to seek release on the grounds of his status as a minor at the time of the offense.

 
 

During the proceedings, it was revealed that Brijnandan's birth date was recorded as October 4, 1984, in school documents and March 10, 1984, on his Aadhaar card. With the offense occurring when he was 17 years and 3 months old, his counsel argued for the recognition of his juvenility under the Juvenile Justice (Care and Protection of Children) Act, 2015. Despite some initial resistance regarding the timing of his application and discrepancies in documentation, the court directed a thorough inquiry into his claim. The inquiry confirmed his birth date and determined that he was indeed a juvenile at the time of the incident.


The court noted that the claim for juvenility can be made at any stage of the criminal process, including post-conviction. Given the findings of the Sessions Judge and the established proof of his age, the court upheld Brijnandan's claim. Consequently, his earlier conviction was set aside, and he was acquitted of the charges.

As Brijnandan had been on interim bail during the proceedings, the court canceled his bail bonds. This ruling not only highlights the judicial system's commitment to protecting the rights of minors but also underscores the importance of accurate documentation in legal proceedings. In a world where juvenile justice often comes under scrutiny, this decision stands as a testament to the principles of fairness and equity, ensuring that individuals are not unjustly punished due to their age at the time of an alleged offense.


THE SCHEDULED CASTES AND THE SCHEDULED TRIBES (PREVENTION OF ATROCITIES) AMENDMENT ACT, 2015    Indian Penal Code, 1860    JUVENILE JUSTICE (CARE AND PROTECTION OF CHILDREN) ACT, 2000