Ram Narain v. State of U.P.
Background
Ram Narain had been convicted and sentenced to life imprisonment under Section 302 IPC for a 1976 murder, and his earlier SLP and review petition challenging the conviction had both been dismissed by the Supreme Court back in 2004. Years later, after already serving more than 10 years in prison, he filed an application before the Juvenile Justice Board claiming he had been a minor (15 years, 11 months, 26 days old, per a school transfer certificate) at the time of the offence; the Board accepted this and declared him a juvenile offender in November 2013. He then approached the Supreme Court seeking release on the strength of this juvenility finding.
Decision Breakdown
The Supreme Court held that a plea of juvenility can be raised at any stage, before any court, regardless of how long after conviction, relying on its own precedents (Upendra Pradhan v. State of Orissa, Ajay Kumar v. State of M.P., Hakim v. State, and Lakhan Lal v. State of Bihar). Since the Juvenile Justice Board had already determined, through the proper procedure, that the petitioner was under 18 at the time of the offence, and he had already spent far longer in custody than the three-year maximum detention period prescribed for juveniles under Section 15 of the Juvenile Justice Act, 2000, the Court set aside the conviction and sentence passed by the Trial Court and High Court and directed his immediate release.
Lesson Learnt
Under Indian law, a claim of having been a minor at the time of an offence can be raised at any point, even decades after conviction, and if proven, entitles the person to release once they have exceeded the maximum detention period applicable to juveniles, regardless of how long they already spent in adult prison under the original sentence.