The Supreme Court has ruled that the Juvenile Justice Board (JJB) lacks the statutory authority to review its own earlier decisions or adopt a contradictory stance in subsequent proceedings. The judgment came in Rajni v. State of Uttar Pradesh & Anr., where the complainant challenged the High Court’s affirmation of a juvenile status declaration and grant of bail to an accused in a murder case.
The case, arising from Criminal Appeal Nos. 603 and 2569 of 2025 before the Supreme Court, dealt with two principal issues: whether the accused (Respondent No. 2) was correctly declared a juvenile on the date of the offence, and whether the High Court erred in granting him bail. The Court upheld the findings of the Additional District and Sessions Judge and the High Court, affirming the juvenile status and bail of Respondent No. 2. Both appeals were dismissed.
The judgment was delivered by a bench comprising Justice Abhay S. Oka and Justice Ujjal Bhuyan.
Background of the Case
Respondent No. 2 was implicated in Crime Case No. 80 of 2021 (under Sections 302/201/34 of IPC) and Crime Case No. 97 of 2021 (under the Arms Act) at Medical College Police Station, Meerut. His mother filed applications before the JJB seeking a declaration of juvenility. These were dismissed on August 27, 2021, with the JJB holding him to be an adult based on a medical board’s assessment.
The accused’s mother appealed, and on October 14, 2021, the Additional District and Sessions Judge reversed the JJB’s decision, accepting a school certificate stating the accused’s date of birth as September 8, 2003, making him 17 years, 3 months, and 10 days old on the date of the incident, February 17, 2021.
Subsequently, the complainant, mother of the deceased, filed Criminal Revision No. 82 of 2022 before the High Court challenging the juvenile status declaration. The High Court dismissed the revision on May 13, 2022.
Arguments of the Parties
The appellant argued that Respondent No. 2 was not a juvenile and had misused provisions of the JJ Act, 2015 to escape liability for a heinous offence under Section 302 IPC. It was submitted that the JJB had correctly relied on medical examination to determine age and that the subsequent judicial findings ignored this evidence. The appellant further contended that Respondent No. 2 had multiple criminal antecedents and that even if treated as a juvenile, a preliminary assessment under Section 15 JJ Act, 2015 was warranted.
Counsel for Respondent No. 2 defended the High Court and Sessions Court orders, asserting that the date of birth in the school certificate was conclusive under Section 94(2) of the JJ Act, 2015. It was submitted that the JJB acted beyond its jurisdiction by rejecting valid documents and seeking medical evidence despite the availability of statutory records.
Court’s Analysis
The Court examined Section 94(2) of the JJ Act, 2015 and the corresponding Rule 12(3) of the JJ Rules, 2007, which mandate a specific order of preference for age determination: (i) matriculation or equivalent certificate, (ii) birth certificate from a school, (iii) municipal birth certificate, and (iv) medical examination only in the absence of these documents.
The Court observed that the JJB erred in rejecting the school certificate and municipal birth certificate, both of which predated the incident, and instead relied on a medical board report stating the accused was “about 21 years” old. The Court held:
“When the concerned birth certificate from the school was available as well as birth certificate issued by the Meerut Municipal Corporation, JJB could not have opted for ossification test. The statute is very clear…”
The bench also noted a crucial inconsistency: in a previous case in 2000, the JJB had accepted the same date of birth (08.09.2003) for Respondent No. 2. The Court ruled:
“It is not open to the JJB to say in subsequent proceeding that date of birth of respondent No. 2 is not 08.09.2003… If this is permitted, it will amount to reviewing its earlier order. The JJ Act, 2015 confers no such power of review upon the JJB.”
Citing Rishipal Singh Solanki v. State of U.P. (2022) 8 SCC 602 and distinguishing Union Territory of J&K v. Shubam Sangra (2022 INSC 1205), the Court reaffirmed that statutory documents must prevail over medical opinion where available.
On Bail and Preliminary Assessment
The Court reviewed the grant of bail by the High Court after the JJB and Sessions Court had earlier denied it. The High Court had observed that gravity of the offence alone was not a ground to deny bail to a juvenile and found no evidence that release would expose the accused to danger or criminal influence.
The Supreme Court noted that the accused had been on bail for over three years without any reported misuse of liberty. It held that no case for interference with the bail order was made out.
On the issue of preliminary assessment under Section 15, the Court recorded that the JJB had already conducted such an assessment and, on December 10, 2021, concluded that the accused had the mental and physical capacity to commit the alleged offence. The matter had been transferred to the Children’s Court. This order was not challenged.
Decision
The Supreme Court dismissed both criminal appeals, finding no grounds to interfere with the High Court’s or the Additional Sessions Judge’s conclusions regarding juvenility or bail. It reiterated the statutory procedure for age determination and held that:
“The JJ Act, 2015 confers no power of review upon the JJB.”
There was no order as to costs.
