Court Upholds Mandatory Timelines Under Juvenile Justice Act, 2015 for Petty Offences
In a significant ruling, the Calcutta High Court has quashed proceedings against a juvenile for failing to adhere to the mandatory timelines stipulated under the Juvenile Justice (Care and Protection of Children) Act, 2015. The case, involving a child in conflict with the law, was represented by his father and was pitted against the State of West Bengal. The judgment was delivered by Dr. Ajoy Kumar Mukherjee, J., on January 27, 2026.
The juvenile had been accused of violating traffic rules in November 2023, including driving without a license and in a rash manner, which led to proceedings under the Juvenile Justice Board (JJB). The inquiry was supposed to be completed within four months from the juvenile's first appearance before the Board, as mandated by Section 14(2) of the Juvenile Justice Act. This period is extendable by a maximum of two months with recorded reasons. However, the proceedings remained inconclusive even beyond this extended period.
The court noted that the failure to conclude the inquiry within the designated timeline automatically leads to the termination of proceedings under Section 14(4) of the Act. This provision is deemed mandatory, aimed at ensuring speedy inquiry and minimizing the negative impact on juveniles. The judgment emphasized that the Juvenile Justice Act is a beneficial legislation, designed to protect and rehabilitate children, and should be interpreted in a manner that advances its objectives.
In delivering the judgment, the court also referenced previous rulings, including the Supreme Court's decision in "Child in conflict with law through his mother v. State of Karnataka," which underscored the importance of adhering to the statutory timeline for inquiries involving petty offences.
The court further highlighted that the provisions of the Juvenile Justice Act should not be misused to escape punishment for serious offences, but in cases of petty offences, the timeline must be strictly followed to uphold the legislative intent.
The decision to quash the proceedings was also influenced by the absence of valid reasons for extending the inquiry period beyond the initial four months. The court found the extension order dated February 2, 2024, lacking in necessary justifications, rendering it invalid under Section 14(2) of the Act.
With this ruling, the Calcutta High Court has reinforced the importance of adhering to statutory timelines in juvenile cases, ensuring that the justice system remains efficient and fair to young individuals in conflict with the law.
Bottom Line:
Juvenile Justice Act, 2015 - Inquiry into petty offences by a child in conflict with law must be completed within four months, extendable by two months with recorded reasons. Failure to conclude inquiry within the prescribed time leads to automatic termination of proceedings under Section 14(4) of the Act.
Statutory provision(s): Juvenile Justice Act, 2015, Sections 14(2), 14(4), 2(45); Indian Penal Code, Sections 279, 205, 332; Motor Vehicle Acts; Bharatiya Nagarik Suraksha Sanhita, Section 528.
