Ram Vijay Singh v. State of Uttar Pradesh
Background
The appellant was convicted for murder (under Section 302 read with Section 34 IPC) for an incident that occurred on 20 July 1982, and his conviction was upheld by the Allahabad High Court. Decades later, he claimed before the Supreme Court that he had actually been a juvenile (under 18) on the date of the offence, relying on a 1982 bail order that had estimated his age as 15½-17½ years and on a family register and Aadhaar card. The High Court got a fresh medical board to examine him in 2020, which placed his age at 40-55 years, but by working backward through hypothetical calculations the High Court still concluded he could have been under 17 at the time of the offence, prompting the State to pursue the matter further and the appellant to invoke this finding before the Supreme Court.
Decision Breakdown
The Supreme Court held that an ossification/medical age test conducted on a person who is already 40-55 years old cannot reliably reconstruct their exact age at an incident 38 years earlier, since such tests are only meaningfully precise near the age of 18 and are not conclusive even then. It also found that an Arms Licence application the appellant himself had filed before the incident recorded his date of birth as 30 December 1961, making him about 21 years old at the time of the offence: direct documentary evidence outweighing speculative medical extrapolation. The Court further rejected the appellant's argument that disbelieving a witness on one co-accused's role should discredit the witness's entire testimony (rejecting the "falsus in uno, falsus in omnibus" maxim), and upheld the conviction based on consistent eyewitness and postmortem evidence of the appellant's role in causing the death with a lathi.
Lesson Learnt
A claim of juvenility can be raised at any stage, even decades later, but it must be backed by reliable documentary proof (school records, birth certificates): courts will not treat a decades-old speculative medical ossification test, especially one performed after age 40, as conclusive proof of a person's age at a long-past incident when contemporaneous official documents say otherwise.