The Chhattisgarh High Court ruled that bail for a juvenile is not an absolute right. It can be denied in serious offense cases where granting bail may compromise the ends of justice and the principles of juvenile rehabilitation.
The Chhattisgarh High Court ruled that bail for a juvenile is not an absolute right and can be denied in cases involving serious offenses where granting bail would compromise the ends of justice.
The Court emphasized that the rehabilitative goals of the Juvenile Justice Act must be weighed against the severity and nature of the crime.
While the law generally favors bail for minors in conflict with the law, exceptions outlined in Section 12 allow for refusal when the offense is serious, the juvenile’s release could expose them to harmful influences, or it would undermine public trust in the justice system.
Justice Arvind Kumar Verma upheld the decisions made by the Juvenile Justice Board and the appellate court, which denied bail to a 16-year-old accused in a murder case, finding no errors in law or jurisdiction that warranted intervention.
The Court noted,
“Juvenile Act is a beneficial legislation intended for reformation of the juvenile/child in conflict with law, but the law also demands that justice should be done not only to the accused, but also to the accuser,”
It stated that when considering bail for a juvenile, the court must account for the relevant facts and circumstances surrounding the case.
The Court found that the evidence presented, including the violent nature of the assault with a sharp weapon, a social investigation report indicating inadequate supervision, and a lack of prima facie evidence for self-defense, justified the decision to deny bail.
The prosecution alleged that the juvenile, alongside co-accused individuals, attacked the victim at night after an altercation, resulting in a fatal abdominal injury. The victim later died from these injuries.
Previously, the Juvenile Justice Board and the appellate court had denied the bail application. In front of the High Court, the defense argued that continued detention would expose the child to criminal influences and psychological harm, claiming the social status report had been misinterpreted.
They also asserted that the incident was one of self-defense and highlighted the juvenile’s lack of prior criminal records and their impoverished background.
The State opposed the bail request, emphasizing the severity of the crime and the findings of the lower courts. Upon reviewing the statutory framework, the Court reiterated that while Section 12 of the Juvenile Justice Act generally favors bail, it also specifies exceptions.
The term “defeat the ends of justice,” the Court explained, is not a mere formality; it allows for consideration of the offense’s nature and gravity, along with other relevant elements like the juvenile’s behavior and the social investigation report.
Dismissing the argument that the crime’s severity is irrelevant for juvenile bail, the Court noted that the legislature would not have included the proviso in Section 12 if bail were intended to be granted as an automatic right in all cases.
Citing the Supreme Court’s decision in Om Prakash v. State of Rajasthan, the Court maintained that while the Juvenile Justice Act is designed to protect, this protection cannot be applied mechanically in serious criminal cases.
The Court found no evidence supporting the claim of self-defense, and acknowledged the social investigation report, which suggested a lack of proper supervision and a risk of the child mingling with undesirable influences if released.
The Court stated that in cases involving serious offenses, the repercussions on society and the victim must be considered when applying the “ends of justice” test. It concluded that justice should be served not only to the juvenile in conflict with the law but also to the victim.
The High Court dismissed the criminal revision, affirming that the lower courts provided well-reasoned rulings after thorough examination of the facts.
Additionally, the Court clarified that its revisional authority under Section 102 of the Juvenile Justice Act is limited and does not allow for a reevaluation of facts unless there is a jurisdictional error.
Case Title: A v. State of Chhattisgarh