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Sanjay Patel & Anr. vs The State of Uttar Pradesh

Special Leave Petition (Crl.) · 2022 INSC 424Decided 13 Apr 2022
Special Leave Petition (Crl.) No. 5604 of 2009
A.M. Khanwilkar · Abhay S. Oka

Background

The applicant was convicted by a Sessions Court in 2006 for murder (Section 302 IPC) for an offence committed in January 2004, and sentenced to life imprisonment; his appeal to the Allahabad High Court and his Special Leave Petition to the Supreme Court were both dismissed by 2009. Years later, he filed a fresh application claiming that, based on his school records, he was actually a juvenile (about 17 years and 7 months old) on the date of the offence and should therefore have been tried under the Juvenile Justice Act instead of as an adult. The Supreme Court had earlier directed the Juvenile Justice Board at Maharajganj to hold an inquiry into this claim.

Decision Breakdown

The Juvenile Justice Board, after examining documentary and oral evidence, held that the applicant's correct date of birth made him a juvenile at the time of the offence, and this finding was not challenged by the State. Under Section 7A of the Juvenile Justice (Care and Protection) Act, 2000, once a court records such a finding, the adult sentence is deemed to have no effect and the person must be sent to the Juvenile Justice Board, which could at most have ordered up to three years in a special home. Since the applicant had already spent over 17 years in custody, far beyond what a Juvenile Justice Board could have imposed, the Court held it would be unjust to send him back to the Board at this stage, and instead directly ordered his immediate release.

Lesson Learnt

A person's claim of having been a juvenile at the time of an offence can be raised and examined even years after a conviction has become final, and if the person has already served longer in custody than the maximum period a Juvenile Justice Board could have ordered, courts will order release rather than mechanically remit the matter to the Board.

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

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