By Tanishka Shah

The Supreme Court of India recently set aside the conviction of a man in a murder case after accepting his claim of juvenility at the time of the incident in 2002, despite his involvement being confirmed in a prior judgment in 2022.
The case stemmed from an incident on January 17, 2002, when a murder was committed in Bhind, Madhya Pradesh. The accused was initially convicted for the crime in 2006 under Section 302 of the IPC (murder), along with Sections 307 (attempted murder) and 34 (common intention), and was sentenced to life imprisonment with a fine. The trial court’s conviction was upheld by the Supreme Court in 2022, but the man later filed an application claiming he was a juvenile at the time of the crime, based on his date of birth.
The accused filed an application after the conviction was upheld, asserting that he was a minor on the date of the incident. He stated his date of birth as October 4, 1984, which would have made him 17 years old at the time of the offense. To verify his claim, the Supreme Court directed an inquiry into his age, which was conducted by the Special Judge, Bhind. The report, dated July 16, 2024, confirmed that his date of birth was indeed October 4, 1984, making him 17 years, 3 months, and 13 days old at the time of the crime.

In light of this evidence, the Supreme Court acknowledged the claim of juvenility, referencing the judgment in Pramila Vs State of Chhattisgarh, which allowed for a juvenility claim even after a conviction had been finalized. The court noted that the Sessions Judge’s inquiry had been thorough, including the testimonies of the applicant, his mother, and the head teacher of the school where he had studied, along with several other supporting documents.

Having considered the submission and the report, the Supreme Court concluded that the applicant was indeed a juvenile at the time of the offense. The court thus set aside the conviction and acquitted the applicant, directing the cancellation of his bail bonds. The bench also noted that the applicant had already served four years and three months of his sentence.

This judgment is significant as it underscores the importance of ensuring juvenile justice, even at later stages in the legal process. It sets a precedent for future cases where claims of juvenility are made after conviction and highlights the necessity for a thorough inquiry into such claims, ensuring that minors are not unjustly subjected to adult criminal penalties. 

Case Title: State of Madhya Pradesh Vs Ramji Lal Sharma & Another

 Citation: CRIMINAL APPEAL NO.293 OF 2022

Click here to read/Download the judgment