By Shazia Siddiqui

The Madhya Pradesh High Court recently upheld the decision to deny bail to a juvenile accused of kidnapping and murdering a minor child, emphasizing that granting bail would undermine societal justice by showing unwarranted sympathy towards the juvenile. The case originated when a Class-XI student went missing after leaving home to attend a temple event. His body was later discovered, revealing a harrowing sequence of events orchestrated by the accused juvenile and an accomplice. They had kidnapped the minor with the intention of demanding a ransom of ₹20 lakh. When their demands went unmet, they callously murdered the young victim and concealed his body.

Initially, the Juvenile Justice Board rejected the bail application filed under Section 12 of the Juvenile Justice (Care and Protection of Children) Act, 2015. This decision was subsequently upheld by the trial court. On appeal, the High Court, through Justice Dinesh Kumar Paliwal, delivered a significant ruling underscoring the complexities involved in balancing juvenile justice with societal interests and victim rights.

Justice Paliwal’s bench emphasized that while the Juvenile Justice Act aims to rehabilitate young offenders, it also serves the crucial purpose of ensuring justice for victims and addressing broader societal concerns. The court condemned the accused juvenile’s actions as reflective of a deeply depraved mindset, rejecting any notion that such heinous acts could be excused as youthful mistakes.

The judgment delved into the dual objectives of the Juvenile Justice Act—reformation of juvenile offenders and restoration of justice for victims. It underscored that the Act does not mandate bail in every instance but requires courts to weigh the gravity of the offense and its impact on society. In this case, the court found the offense to be particularly egregious—an innocent child was kidnapped and murdered over ransom, demonstrating severe moral turpitude.

Justice Paliwal’s bench stressed that while the Act prioritizes the welfare of juveniles, it equally demands justice for victims and societal interests. The court’s decision reflected a careful consideration of these dual imperatives, asserting that denying bail in this instance was necessary to uphold public confidence in the justice system and ensure accountability for the crime committed.

Moreover, the High Court’s ruling highlighted the importance of interpreting bail provisions judiciously, not as automatic entitlements for juveniles, but as considerations subject to the circumstances of each case. It rejected arguments that sympathy alone should dictate bail decisions, emphasizing instead the need for a balanced approach that respects both the rights of the accused and the interests of justice.

In conclusion, the Madhya Pradesh High Court affirmed the lower courts’ decisions to deny bail to the juvenile accused, emphasizing the gravity of the offense and its impact on society. The ruling underscored the court’s commitment to ensuring justice for victims of serious crimes while recognizing the rehabilitative goals of the Juvenile Justice Act. By dismissing the criminal revision and upholding the denial of bail, the court reinforced the principle that juvenile justice must be tempered with accountability and societal welfare. This case serves as a poignant reminder of the delicate balance required in adjudicating cases involving juvenile offenders and the enduring need for justice in our legal system.

Case Title: Child Under Conflict With Law v. The State of Madhya Pradesh

Citation: CRIMINAL REVISION NO.1300/2024

Click here to read/Download the judgement