Introduction: In Pramila v. State of Chhattisgarh (2024 Latest Caselaw 39 SC), the Supreme Court held that an accused who was a juvenile on the date of the offence could not be sentenced to imprisonment under the Juvenile Justice Act, 1986. The Court set aside her conviction and sentence after finding that she was below 18 years of age at the time of the incident.
Facts of the Case The appellant had been convicted for offences under Sections 302 and 201 read with Section 34 of the Indian Penal Code and was sentenced to life imprisonment. During the hearing of her appeal before the Supreme Court, she raised the plea that she was a juvenile when the alleged offence was committed. The Supreme Court directed the Sessions Court to conduct an inquiry into her age. The inquiry relied upon school records, including the school leaving register and the primary examination certificate, which consistently recorded her date of birth as 1 September 1982. Based on this evidence, it was found that on the date of the incident, 15 June 2000, the appellant was 17 years, 9 months and 14 days old. Issue Before the Supreme Court The principal issue was whether the appellant was a juvenile on the date of the offence and, if so, whether her conviction and sentence of life imprisonment could be sustained.
Supreme Court's Findings The Supreme Court accepted the findings of the age inquiry and held that the appellant was a juvenile at the time of the offence. The Court observed that since the offence had taken place before the Juvenile Justice (Care and Protection of Children) Act, 2000 came into force, the case was governed by the Juvenile Justice Act, 1986. Under the 1986 Act, a girl who had not attained the age of 18 years was treated as a juvenile. The Court noted that the 1986 Act prohibited sentencing a juvenile to imprisonment. Instead, the maximum measure that could have been adopted was sending the juvenile to a special home for the period prescribed under the Act. The Court further observed that the appellant had already undergone more than eight years of imprisonment, which was far beyond the maximum period permissible under the juvenile justice law. In these circumstances, there was no purpose in remitting the matter to the Juvenile Justice Board.
Final Decision
The Supreme Court allowed the appeal and: •Set aside the conviction and sentence against the appellant. •Held that she was a juvenile on the date of the offence. •Declined to remand the matter to the Juvenile Justice Board since she had already undergone more than eight years of incarceration. •Cancelled her bail bonds.
Significance of the Judgment This judgment reiterates that the plea of juvenility can be raised even at a later stage of criminal proceedings if supported by reliable evidence. It also reinforces that a juvenile cannot be sentenced to imprisonment in violation of the Juvenile Justice Act. The decision highlights the Supreme Court's commitment to ensuring that the statutory protections available to children in conflict with law are fully respected, even after conviction.
