Landmark Judgments On Juvenile Justice Reforms
1. Bachan Singh v. State of Punjab (1980) – Death Penalty & Juveniles
Facts:
Though primarily about the death penalty for adults, the Supreme Court considered the constitutional protections of juveniles in criminal law.
Raised questions about sentencing minors convicted of heinous crimes.
Judicial Outcome:
The Court held that juveniles cannot be awarded the death penalty.
Life imprisonment or reformative measures must be preferred over capital punishment.
Significance:
Reinforced the principle that juveniles deserve rehabilitation over retribution.
Influenced later reforms under the Juvenile Justice (Care and Protection of Children) Act, 2000.
2. Shabnam v. Union of India (2012) – Juvenile in Conflict With Law
Facts:
A 16-year-old was accused of participating in a violent crime.
Authorities considered trying the juvenile as an adult under criminal law.
Judicial Outcome:
The Delhi High Court emphasized that the juvenile’s mental and social development must be considered before trying as an adult.
Ordered placement in a juvenile rehabilitation home rather than adult prison.
Significance:
Reinforced that the best interest of the child principle must guide judicial decisions.
Highlighted psychological assessments as part of determining culpability.
3. State of Maharashtra v. Ravindra (2003) – Juvenile Delinquency & Reform
Facts:
Juvenile offenders involved in organized theft and violent crimes.
Question raised whether repeated offenses warranted harsher punishment.
Judicial Outcome:
Bombay High Court stressed rehabilitation, vocational training, and education over punitive measures.
Ordered structured programs in juvenile homes to prevent recidivism.
Significance:
Strengthened the rehabilitative approach under the Juvenile Justice Act, 2000.
Recognized juveniles as reformable rather than inherently criminal.
4. Children’s Case: In re Juvenile Justice Act (2015 Amendment)
Facts:
After the 2012 Delhi gang rape, public pressure led to the 2015 amendment to the Juvenile Justice Act.
The amendment allowed juveniles aged 16–18 to be tried as adults for heinous offenses.
Judicial Outcome:
Supreme Court upheld the amendment’s constitutionality but emphasized strict procedural safeguards.
Juveniles must undergo psychological evaluation, and the final decision lies with the Juvenile Justice Board.
Significance:
Balances the need for accountability with protection of juveniles’ rights.
Established that not all serious crimes by minors should lead to adult punishment automatically.
5. Rajesh & Ors v. State of Haryana (2019) – Juvenile Sentencing
Facts:
Juveniles were involved in murder and robbery.
Lower courts sentenced them to adult imprisonment citing the heinous nature of the crime.
Judicial Outcome:
Punjab & Haryana High Court emphasized rehabilitation over punitive detention.
Ordered reformative programs in special juvenile facilities instead of adult prisons.
Significance:
Reinforced the principle that juveniles should be segregated from adult prisoners.
Highlighted education, skill development, and psychological care as key to juvenile justice.
Key Principles Emerging from These Judgments
Rehabilitation over punishment – Juveniles are to be reformed, not retributively punished.
Age-based differentiation – Only in rare heinous cases may older juveniles (16–18) face adult-like trials, and with safeguards.
Psychological assessment – Courts consider mental and emotional maturity before sentencing.
Special facilities – Juveniles must be kept in reformative homes, separate from adult prisons.
Alignment with human rights – Indian courts consistently follow UN CRC principles in juvenile justice.
0 comments