The Supreme Court in a recent order acquitted a woman who was sentenced to suffer life-imprisonment for committing an offence of murder, after finding that she was a juvenile in 2000 when the offence took place.
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NEW DELHI: The Supreme Court of India acquitted a woman in a 23-year-old murder case, citing her juvenile status at the time of the offence. This decision, overturning the concurrent findings of the High Court and the Trial Court, was delivered by the Bench of Justices Abhay Oka and Ujjal Bhuyan.
The case involved Pramila, who was convicted of murder (dated June 15, 2000) and sentenced to life imprisonment by the trial court. Her appeal to the High Court was dismissed, maintaining her sentence. Challenging this decision, Pramila approached the Supreme Court.
During the Supreme Court hearing, Pramila’s defense argued her ‘juvenility’ at the time of the offence. After examining the birth records, the Court confirmed that Pramila was indeed a juvenile when the crime occurred. The Court stated,
“Therefore, we have to proceed on the footing that on the date on which the incident constituting the offence took place, the age of the appellant was less than 18 years.”
The Court noted that Pramila’s case fell under the old Juvenile Justice Act, 1986, which defines a juvenile girl as someone who has not attained the age of eighteen years.
“The Juvenile Justice (Care and Protection of Children) Act, 2000 (for short, ‘the 2000 JJ Act’) was admittedly not in force when the incident occurred. Therefore, the case will be governed by the Juvenile Justice Act, 1986 (for short, ‘the 1986 JJ Act’). Under clause (h) of Section 2 of the 1986 JJ Act, a ‘juvenile’ has been defined to mean a boy who has not attained the age of sixteen years or a girl who has not attained the age of eighteen years. Thus, on the date of occurrence of the offence, the appellant was a juvenile.”
– Court stated.
The Court further observed that the imposition of a life sentence was not justified under the JJ Act, which stipulates a maximum punishment of up to three years in a special home for juveniles.
“In the case of a girl of sixteen years of age, she could have been sent to a special home for a period of not less than three years. As per Section 22(1) of the 1986 JJ Act, there was a prohibition on sentencing a juvenile to undergo imprisonment. There is a similar provision under Section 16 of the 2000 JJ Act.”
– Court further stated.
Considering that Pramila had already served eight years in incarceration, the Court declined to send her before the Juvenile Justice Board. The Court concluded,
“Hence, the present Appeal must succeed and the impugned judgment and order dated 3rd May, 2010 passed by the High Court and the impugned judgment and order dated 30th June, 2003 passed by the Additional Sessions Judge, Ramanujganj, District Sarguja, Chhattisgarh, are hereby quashed and set aside only insofar as the appellant (accused no.2) is concerned.”
This ruling is a significant reminder of the importance of considering the age and juvenile status of individuals at the time of the offence, ensuring that the principles of juvenile justice are upheld in the legal system.
Case Details:
PRAMILA VERSUS STATE OF CHHATTISGARH
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