Supreme Court Acquits Man Convicted of Murder Due to Juvenility Claim
The case of State of Madhya Pradesh vs. Ramji Lal Sharma & Another involved a crucial legal issue regarding juvenility claims in criminal cases. The Supreme Court, in its judgment dated September 23, 2024, set aside the conviction of the applicant, Brijnandan @ Brajesh Sharma, after confirming that he was a juvenile at the time of the offense. The Court ruled that under the Juvenile Justice (Care and Protection of Children) Act, 2015, the applicant was entitled to legal protection despite the late stage of his claim.
This case highlights the retrospective application of the juvenile justice law and the principle that juvenility can be raised at any stage of the legal proceedings, including after a conviction.
Background of the Case
The case stemmed from a murder incident that occurred on January 17, 2002, in Bhind, Madhya Pradesh. The applicant, Brijnandan @ Brajesh Sharma, was convicted alongside other accused individuals under:
- Section 302 (Murder) read with Section 34 IPC (common intention).
- Section 3(2)(v) of the SC/ST (Prevention of Atrocities) Act, 1989.
The case underwent multiple appeals:
- The Trial Court convicted the accused in 2006 and sentenced them to life imprisonment.
- The Madhya Pradesh High Court acquitted the accused in 2018, citing lack of evidence.
- The Supreme Court, in 2022, overturned the High Court’s decision and restored the conviction and life sentence.
It was only after serving four years and three months of his sentence that the applicant filed a claim of juvenility, arguing that he was 17 years and 3 months old at the time of the offense.
Legal Proceedings
Application for Juvenility Claim
- The applicant, through his counsel, moved the Supreme Court seeking release based on his juvenile status under the Juvenile Justice Act, 2015.
- He presented school records showing his date of birth as October 4, 1984, making him 17 years, 3 months, and 13 days old on the date of the offense.
State’s Objections
The State of Madhya Pradesh opposed the plea, arguing:
- The claim was belated, as it was raised only after the Supreme Court had upheld his conviction.
- There were discrepancies in his name across different documents, with variations such as Brijnandan and Brajesh Sharma.
- The Aadhaar Card listed a different date of birth (March 10, 1984), raising doubts about the authenticity of his claim.
Supreme Court’s Observations
The Supreme Court, comprising Justices B.V. Nagarathna and Nongmeikapam Kotiswar Singh, directed the Sessions Court in Bhind, Madhya Pradesh, to conduct an inquiry into the applicant’s age.
Findings of the Sessions Court
- The inquiry, conducted on July 16, 2024, concluded that the applicant’s official date of birth was indeed October 4, 1984.
- On the date of the offense, the applicant was confirmed to be under 18 years old.
- The applicant’s mother and school officials testified to support his claim.
Supreme Court’s Ruling
- The Court held that juvenility can be raised at any stage, even after conviction, relying on the precedent set in Abuzar Hossain vs. State of West Bengal (2012).
- It cited Pramila vs. State of Chhattisgarh (2012), affirming that claims of juvenility should be considered, irrespective of delays in filing.
- The Court accepted the Sessions Court’s findings and ruled that the applicant was entitled to the benefits of the Juvenile Justice Act.
Important Excerpts from the Judgment
“The principle that juvenility may be raised at any stage of criminal proceedings, including after conviction, is well settled. The applicant’s date of birth as recorded in official school documents is to be accepted.”
“Having regard to the report of the learned Sessions Judge and the testimonies of the witnesses, the applicant is found to be entitled to the benefit of the Juvenile Justice Act.”
Final Judgment
The Supreme Court ruled:
- The conviction of Brijnandan @ Brajesh Sharma was set aside.
- The applicant was acquitted on account of being a juvenile at the time of the offense.
- His interim bail was made permanent, and his bail bonds were cancelled.
Implications of the Judgment
This ruling has significant legal implications:
- Retrospective Application of the Juvenile Justice Act: The decision confirms that juvenility claims can be raised even after a final conviction.
- Judicial Consideration of Delay in Juvenility Claims: Courts must assess the merits of a claim regardless of when it is raised.
- Verification Standards for Juvenility: Official school records take precedence in determining a person’s age over other documents.
- Reinforcement of Juvenile Rights: The ruling protects the rights of juveniles by ensuring that no underage person is punished as an adult.
The Supreme Court’s decision strengthens the juvenile justice system by ensuring that juveniles, even if convicted and sentenced, are not denied their legal protections due to procedural delays.
Petitioner Name: State of Madhya Pradesh.Respondent Name: Ramji Lal Sharma & Another.Judgment By: Justice B.V. Nagarathna, Justice Nongmeikapam Kotiswar Singh.Place Of Incident: Bhind, Madhya Pradesh.Judgment Date: 23-09-2024.
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