Om Prakash @ Israel @ Raju @ Raju Das vs. Union of India & Anr., Criminal Appeal No. 4229 of 2024

The Supreme Court of India, in Om Prakash @ Israel @ Raju @ Raju Das vs. Union of India & Anr. [Criminal Appeal No. 4229 of 2024, decided January 8, 2025], delivered a landmark judgment on the retrospective application of juvenile justice principles and the protection of juveniles’ rights in the criminal justice system.

Facts and Background
Om Prakash was convicted and sentenced to death for an offense committed in 1994. At trial in 2001, he stated his age as 20, but later claimed he was only 17 at the time of the offense. The trial court and subsequent appellate courts did not adequately examine his juvenility claim, relying instead on his own statements and circumstantial evidence. After his conviction and rejection of review and curative petitions, an ossification test and medical certificate established that Om Prakash was around 14 years old at the time of the crime. During the pendency of his mercy petition, the President commuted his death sentence to life imprisonment with a stipulation that he would not be released until the age of 60.

Legal Issues
Whether Om Prakash was a juvenile at the time of the offense and entitled to the protections of the Juvenile Justice (Care and Protection of Children) Act.

Whether the failure to determine his age at the trial stage vitiated the proceedings.

The appropriate remedy under the Juvenile Justice Act, 2015, and the constitutional implications of procedural lapses.

Supreme Court’s Findings
The Supreme Court meticulously examined documentary evidence, including school records and medical reports, and applied Section 94 of the Juvenile Justice Act, 2015, which governs age determination. The Court held that in cases of doubt, the benefit must go to the accused if there is reasonable evidence of juvenility. It found that Om Prakash was indeed a juvenile at the time of the offense.

The Court criticized the systemic lapses and judicial oversight that led to the miscarriage of justice, emphasizing that the protection under the Juvenile Justice Act is aimed at rehabilitation, not punishment. The Court set aside the life sentence, ordered Om Prakash’s release, and directed that he be treated as per the provisions of the Juvenile Justice Act, underscoring the primacy of reformative over punitive measures.

Conclusion
This judgment:

Reinforces the constitutional and statutory rights of juveniles, ensuring minors are not wrongfully subjected to adult criminal penalties.

Affirms that age determination must be rigorously verified in criminal trials involving young offenders.

Sets a precedent for re-examination and relief in cases where juvenility claims were overlooked.

Reiterates the judiciary’s duty to prioritize substantive justice and the best interests of children over procedural rigidity.