Darga Ram @ Gunga v. State of Rajasthan
Background
In April 1998, a seven-year-old girl, Kamala, went missing from a night-long prayer gathering (Jaagran) in Rajasthan and was later found raped and murdered. The appellant was tried, convicted under Sections 302 and 376 IPC, and sentenced to life imprisonment plus a fixed-term sentence; the Rajasthan High Court dismissed his appeal. Before the Supreme Court, the appellant raised a claim that he was a juvenile (under 18) on the date of the offence and so entitled to protection under the Juvenile Justice Act, relying on a medical board's age estimate.
Decision Breakdown
The Supreme Court examined the medical board's report, which estimated the appellant's age at "about" 33 years at the time of examination (around 14 years after the offence), spanning a range of 30 to 36 years. Applying Rule 12(3)(b) of the Juvenile Justice Rules, which allows courts to give the benefit of the doubt by fixing age on the lower side by up to one year when exact assessment isn't possible, the Court found that even taking the upper end of the estimated range, the appellant would have been about 17 years 2 months old at the time of the offence, making him a juvenile. The Court affirmed the conviction for rape and murder as factually correct, but set aside the sentence (life imprisonment and the other sentence) because the appellant was legally a juvenile at the time, directing he be released from prison (having already served about 14 years) unless wanted in any other case.
Lesson Learnt
Even where a serious crime is proved, a convict who was under 18 years old at the time of the offence is legally entitled to juvenile-justice protection from adult sentencing, and when medical age evidence is uncertain, courts must apply the statutory benefit-of-doubt margin in the accused's favour.