Narayan Chetanram Chaudhary vs. The State of Maharashtra
Background
The applicant, tried and sentenced to death in 1998 as "Narayan Chetanram Chaudhary" for the 1994 murder of five women and two children in Pune, had never raised a claim of juvenility during his trial, appeal, or first review, all of which were dismissed by 2000, with the Supreme Court itself confirming his death sentence and rejecting an earlier Article 32 petition on juvenility in 2013. Years later, aided by human-rights advocates, he claimed his real name was "Niranaram Chetanram Chaudhary" and produced school records and other documents showing a date of birth that would have made him only about 12 years and 6 months old at the time of the offence, far below the age of criminal majority.
Decision Breakdown
The Supreme Court had earlier directed the Principal District and Sessions Judge, Pune to conduct a factual inquiry into the juvenility claim, which found the school certificates, admission-register entries, and other government records genuine and concluded the applicant was indeed a juvenile at the time of the offence. The Court held that once an applicant discharges the burden of producing an authentic school-based date-of-birth certificate under Section 94 of the 2015 Act, the State must produce compelling contrary evidence to disprove it, which the State and the complainant here failed to do, relying instead only on inconsistencies among the applicant's own other documents. The Court also rejected the argument that the extreme gravity of the crime should override a genuine finding of juvenility, holding that the seriousness of an offence cannot by itself be a ground to deny the statutory protection given to child offenders (barring the specific heinous-offence exception under Section 15, which did not apply here). Accepting the Inquiring Judge's finding that the applicant was about 12 years and 6 months old at the time of the crime, the Court declared his death sentence invalid by operation of law and ordered his immediate release, since he had already spent over 28 years in custody, far beyond the maximum detention period permissible for a juvenile offender.
Lesson Learnt
A person's claim of having been a minor ("juvenile") at the time of an offence can be examined and accepted even decades after conviction if genuine documentary proof (such as an authentic school record) surfaces, and once the age is proven, the law does not allow the severity of the crime to override the special protections the law gives to child offenders, even for a crime as grave as a multiple murder carrying a death sentence.