LegalAware
LegalAware.ai
EMPOWERING LEGAL AWARENESS

Rahul Kumar Yadav vs. The State of Bihar

Not available · 2024 INSC 359Decided 25 Apr 2024
Not available
Justice B.R. Gavai · Justice Sandeep Mehta

Background

The appellant, Rahul Kumar Yadav, was convicted along with a co-accused by a Sessions Court in Darbhanga, Bihar for murder and robbery under the IPC and the Arms Act, and was originally sentenced to death. The Patna High Court's Division Bench gave a split verdict, and a third judge ultimately dismissed the appeal but commuted the sentence to life imprisonment. Even before the trial began, the appellant had twice tried, and failed, to get the courts to recognize him as a juvenile at the time of the 2011 offence, first relying on his horoscope and later on a birth certificate, but both the Magistrate and the trial court rejected these claims without a proper inquiry.

Decision Breakdown

The Supreme Court held that a claim of juvenility can be raised at any stage of proceedings (even for the first time before the Supreme Court itself, or after final disposal of a case) and delay alone cannot be a ground to reject it, relying on its earlier rulings in Abuzar Hossain vs. State of West Bengal and Vinod Katara vs. State of Uttar Pradesh. It found that neither the trial court nor the High Court had ever conducted a proper inquiry into the appellant's age despite his claim being raised at the earliest opportunity. The Court therefore directed the Additional Sessions Judge, Darbhanga to conduct a thorough inquiry into the appellant's actual age/date of birth within 12 weeks, using an ossification (bone) test as a last resort if documentary evidence proves inconclusive, and listed the matter for further hearing in August 2024.

Lesson Learnt

A person's claim to have been a minor (juvenile) at the time of an alleged offence must be properly investigated by the courts and can be raised at any point, even years after conviction or for the first time before the Supreme Court, because age at the time of the offence determines whether a person should be tried as a child rather than as an adult.

Official source (sci.gov.in)View Judgment (PDF)

More rulings in Criminal Law

Criminal LawSupreme Court of India

Charming Rupon v. State of Meghalaya

The Supreme Court acquitted the accused, finding the prosecution's case riddled with serious doubt. Both the victim and her cousin (a key witness) admitted in cross-examination that they could not identify the accused and that his name had been supplied to them by the victim's mother, raising a strong suspicion of tutoring, especially since the victim admitted she had been coached by the public prosecutor before testifying. The mother's own conduct (not reacting urgently despite being told of the assault, and material facts missing from the belated FIR) was found "unnatural." A crucial witness, the school teacher whose disclosure triggered the FIR, was never examined, without explanation, warranting an adverse inference against the prosecution. The Court also noted that two medical witnesses were never meaningfully cross-examined because the defence counsel was absent on the relevant dates, and that the trial court had wrongly brushed aside credible alibi evidence led by the accused.

Decided 9 Oct 2026Read case
Criminal LawSupreme Court of India

Ramkrushna Prahllad Dongardive v. The State of Maharashtra

The Supreme Court restored the trial court's acquittal. It found that the prosecution never produced the original cashbooks, daily registers, or audit reports that would have actually proven the appellant was entrusted with and misappropriated the money: the investigating officer himself admitted these documents were never shown to him despite being asked for. The department also failed to produce records the appellant had specifically sought in his own defence. Separately, the search and seizure of documents from the appellant's house was legally doubtful, since both independent witnesses to the seizure turned hostile and denied knowing its contents, and the mandatory procedural safeguards for such a seizure were not followed. The Court also flagged that the High Court convicted the appellant for the very first time on appeal without ever hearing him on the question of sentence, which the law required it to do.

Decided 8 Oct 2026Read case
Criminal LawDelhi High Court

Gurpreet Singh vs. State (NCT of Delhi)

The Court accepted that the order recalling the proclaimed offender status be placed on record. Noting that the complainant was untraceable and the prosecution itself raised no serious objection to anticipatory bail, the Court found no reason to deny the applicant liberty. It granted anticipatory bail, directing release on a personal bond of Rs. 20,000 with one surety in the event of arrest.

Decided 7 Oct 2026Read case
Criminal LawDelhi High Court

Mukesh Rani vs. Narcotics Control Bureau

The Court noted the investigation was complete, the chargesheet was filed, the co-accused had already been granted bail, and the combined quantity recovered (1.976 kg) still fell short of the "commercial quantity" threshold under the NDPS Act. With ten witnesses yet to be examined and no indication the trial would conclude quickly, the Court found continued detention unnecessary and granted regular bail on a personal bond of Rs. 50,000 with standard conditions.

Decided 7 Oct 2026Read case
Criminal LawDelhi High Court

Aakash vs. State Govt. of NCT of Delhi and Anr.

The Court noted that all prosecution witnesses, including the complainant and the guest house manager, had already been examined, and that a co-accused in the same FIR had already been granted bail. Given the complainant's own testimony about voluntary association with the petitioner and the completed trial evidence, the Court found the overall facts favoured bail. It granted regular bail on a personal bond of Rs. 50,000 with standard conditions (reporting to police weekly, not influencing witnesses, providing address/mobile details).

Decided 7 Oct 2026Read case
Criminal LawDelhi High Court

Kundan Kumar vs. State NCT of Delhi & Anr.

The Court relied on earlier Delhi High Court rulings holding that whether a broken promise of marriage was "false" from the outset (criminal) or a mere "breach" (not criminal) is a question for trial, not something requiring custodial interrogation. Noting the investigation was complete and the applicant had no prior criminal record, the Court granted regular bail on a personal bond of Rs. 25,000 with conditions, clarifying the order was not an opinion on the merits.

Decided 7 Oct 2026Read case