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Vinod Prajapati @ Bhola Prajapati vs. The State of NCT of Delhi

Criminal Appeal · 2026:DHC:8299-DBDecided 25 Sept 2026New Delhi Bench
CRL.A. 297/2004CNR: DLHC010095152004
Justice Navin Chawla · Justice Ravinder Dudeja

Background

The appellant was convicted in 2004 of murdering and robbing an elderly woman, Lado Devi, while working as her domestic servant in 1995, and sentenced to life imprisonment. Decades later, he claimed he had been a juvenile (under 18) at the time of the offence, relying on a school mark-sheet showing his age as about 17, later verified as genuine by the education board, as well as a 2005 bone-age (ossification) medical test conducted on court orders.

Decision Breakdown

The Court held that under Supreme Court precedent (Hari Ram, Dharambir), a person who was under 18 at the time of an offence is entitled to juvenile protection regardless of when this claim is raised, even decades later and even if committed before the modern juvenile law existed. Both the verified school certificate and the ossification test independently confirmed the appellant was under 18 in 1995, so the Court did not disturb the underlying conviction (which it independently reviewed and found well-supported by evidence including recovered bloodstained clothing) but quashed the sentence itself, since juveniles cannot be detained beyond three years, and ordered his release given he had already served over seven years.

Lesson Learnt

A genuine claim of juvenility can succeed and result in release from a life sentence even many years after conviction, but it affects only the sentence: the underlying conviction can still stand if the evidence otherwise proves guilt.

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