Rishipal Singh Solanki v. State of Uttar Pradesh
Background
In a violent incident in 2020, the appellant's father and uncle were killed, and one of the accused, a minor named Nishant, claimed he was a juvenile at the time of the offence. The Juvenile Justice Board, relying mainly on his matriculation certificate showing a date of birth of 25.09.2004, declared him a juvenile delinquent, a finding upheld on appeal by the Sessions Court and then by the Allahabad High Court. The victim's son (the appellant) challenged this before the Supreme Court, arguing that the age-determination process was flawed and that Nishant was actually an adult who should face trial as such.
Decision Breakdown
The Supreme Court examined the evidence of age, including the matriculation certificate and a corroborating verification letter from the education authority, and found no contrary medical or documentary evidence (such as Aadhaar or voter ID records) that contradicted the recorded date of birth, unlike in a previous precedent the appellant relied on. It reaffirmed the legal hierarchy for age determination under Section 94 of the Juvenile Justice Act, 2015, school/matriculation records first, then municipal birth certificates, and only then medical/ossification tests as a last resort, and held that this hierarchy had been properly followed here. Finding the age of 15 years and 7 months (below the 16-year threshold) correctly established, the Court dismissed the appeal and upheld the finding of juvenility.
Lesson Learnt
When determining whether an accused person is a juvenile, courts must follow a strict order of evidence, school and matriculation records take priority over medical tests, and a documented date of birth will stand unless credible contrary evidence specifically contradicts it.