SUPREME COURT REJECTS JUVENILITY CLAIM IN MURDER CASE, PREFERS STATUTORY PROOF OVER SCHOOL RECORDS:

On Friday, August 1, the Supreme Court of India ruled that an accused in a 2012 murder case could not be considered a juvenile at the time of the offence, thereby overturning the findings of both the Trial Court and the High Court. The judgment came in response to an appeal filed by the complainant, challenging the earlier decisions that had accepted the accused’s claim of juvenility based solely on school records.

A Bench comprising Justices Pankaj Mithal and Ahsanuddin Amanullah observed that the lower courts had erred by relying exclusively on a certificate issued by a private school—Kaushik Modern Public School—which recorded the accused’s year of birth as 1995. This date would make him under 18 at the time of the offence. However, the Supreme Court noted that this school record was based entirely on the oral statement of the accused’s father, provided at the time of admission, without any supporting documentary proof.

In contrast, the Court pointed out that more reliable public documents were available that clearly indicated a different year of birth. These included the Family Register maintained under the Uttar Pradesh Panchayat Raj Act, 1947, and the Voter List for the 2012 Legislative Assembly elections. Both of these public records consistently recorded the accused’s birth year as 1991. In addition, a medical report issued by the Chief Medical Officer of Muzaffarnagar supported this finding, opining that the accused was approximately 22 years old on December 1, 2012.

The Supreme Court emphasized that under Rule 12(3) of the Juvenile Justice (Care and Protection of Children) Rules, 2007, while school records may be relevant in determining the age of an accused, they are not to be treated as conclusive when more credible evidence is available. The Court clarified that the rule does not prohibit the consideration of other statutory or public documents, particularly when such documents present a consistent and reliable account of the individual’s age.

In its detailed judgment, the Court highlighted the distinction between documents based on verifiable data and those based on unverified oral declarations. The bench observed that the certificate issued by the school was made solely on the basis of the father’s statement and had no supporting proof, while the Family Register, Voter List, and medical examination report were all official records maintained by public authorities and aligned with each other in indicating the accused’s birth year as 1991.

The Court concluded that the reliance on the school certificate was misplaced and that it could not override the evidentiary value of the statutory documents. As such, the earlier decisions treating the accused as a juvenile were deemed “plainly improper” and were set aside. The Supreme Court held that the accused should be treated as a major at the time of the incident and tried accordingly for the offence committed under Crime No. 385/2011, Police Station – Kairana.

Allowing the appeal, the Court directed that the accused be prosecuted as an adult, reaffirming the primacy of statutory records in matters involving the determination of age for criminal liability.