Supreme Court Quashes Conviction Due to Non-Compliance with Juvenile Justice Act, Conviction of a Minor in Haryana Overturned for Procedural Lapse in Trial as an Adult
In a landmark judgment, the Supreme Court of India has overturned the conviction of Sagar, a minor from Haryana, who was sentenced to 14 years of rigorous imprisonment after being tried as an adult. The apex court found that the trial failed to comply with mandatory provisions under the Juvenile Justice (Care and Protection of Children) Act, 2015, specifically the requirement for a Children's Court to pass a reasoned order under Section 19(1) after receiving a preliminary assessment report from the Juvenile Justice Board.
The case dates back to October 2018, when Sagar, then 16 and a half years old, was accused of being involved in a fatal assault on Mandeep Kumar. He was initially assessed by the Juvenile Justice Board, which recommended he be tried as an adult. However, the Children's Court, which took up the trial, neglected to issue a necessary order under Section 19(1) of the Act, which mandates a decision on whether the accused should be tried as an adult or as a child.
The Supreme Court, led by Justices Aravind Kumar and Prasanna B. Varale, emphasized that Section 19(1) is substantive and mandatory. The failure to comply with this provision resulted in a vitiated trial, rendering the proceedings illegal. Consequently, the Court quashed the conviction and sentence, noting that the appellant, who is now 24 years old, had already spent over six years in incarceration, and a remand for reassessment was deemed impractical.
The judgment highlights the critical importance of procedural compliance to safeguard the rights of minors in conflict with the law. The Court directed Children's Courts nationwide to ensure adherence to the statutory requirements, reinforcing the protective framework intended by the Juvenile Justice Act.
Statutory provision(s): Juvenile Justice (Care and Protection of Children) Act, 2015, Sections 15, 18(3), 19(1), 21; Indian Penal Code, Sections 148, 149, 302, 323, 341; Code of Criminal Procedure, 1973, Section 161.
Sagar v. State of Haryana, (SC) : Law Finder Doc id # 2939853
