Juvenile Justice (Care and Protection of Children) Act, 2015 — Section 94 — Determination of age — Hierarchical evidentiary rule — Primacy of matriculation/school records over Aadhaar — Scope of revisional interference under Sections 397 and 401 Cr.P.C. (Paras 20–22, 24–27)
The revision challenged the order of the Juvenile Justice Board declaring Respondent Nos. 2 and 3 as juveniles in conflict with law. The petitioner relied upon Aadhaar cards to contend that the respondents were above 18 years on the date of the offence and further urged that the Trial Court ought to have ordered medical examination.
The High Court held that Section 94 of the Juvenile Justice Act mandates a structured evidentiary hierarchy, placing matriculation certificates, S.S.C. mark lists, and Transfer Certificates at the highest pedestal. Only in the absence of such documents can birth certificates or medical opinion be considered. Since S.S.C. records were available and verified by the Investigating Officer, the Juvenile Justice Board rightly relied upon them. Aadhaar card entries cannot override statutory school records.
The Court further held that ossification test is a last resort and becomes redundant where primary documentary evidence exists.
Ratio Decidendi: When matriculation or equivalent school records are available and duly verified, Section 94 of the Juvenile Justice Act confers primacy upon such documents for age determination; Aadhaar entries or speculative medical tests cannot displace them, and revisional jurisdiction cannot be invoked to reappreciate such findings absent perversity.
Aadhaar Card — Evidentiary value in age determination — Not conclusive proof of date of birth. (Paras 13, 22)
The petitioner relied upon Aadhaar cards reflecting year of birth as 1999. The Court, relying on binding precedent including Saroj v. Iffco-Tokio General Insurance Co., held that Aadhaar is intended as proof of identity, not proof of date of birth. UIDAI circulars also clarify that Aadhaar per se is not proof of date of birth.
Ratio Decidendi: Aadhaar card entries regarding date of birth are not conclusive proof for determination of juvenility under Section 94 of the Juvenile Justice Act and cannot override verified school records.
Medical Examination/Ossification Test — When permissible — Residual category. (Paras 21, 24)
The petitioner contended that the Board should have directed a medical board examination. The Court held that medical opinion can be sought only in the absence of matriculation or school records, in consonance with the statutory mandate and settled law. After seven years from the date of offence, ossification test would be unreliable.
Ratio Decidendi: Medical examination for age determination is permissible only when statutory documentary evidence under Section 94(2) of the Juvenile Justice Act is unavailable; it cannot be ordered as a matter of course.
Plea of Juvenility — Can be raised at any stage — Prior proceedings irrelevant — No estoppel against statutory benefit. (Para 23)
The petitioner argued that Respondent No. 2 was earlier treated as an adult in C.C. No. 1904/2017 and did not claim juvenility. The Court held that under the Juvenile Justice Act, plea of juvenility can be raised at any stage, and failure to raise it in earlier proceedings does not extinguish the statutory right. Doctrine of estoppel does not operate against minors in matters of statutory protection.
Ratio Decidendi: The right to claim juvenility is a statutory protection that can be invoked at any stage; prior non-assertion or compromise in earlier proceedings does not bar such plea.
Revisional Jurisdiction — Scope under Sections 397 and 401 Cr.P.C. — Limited supervisory power. (Paras 20, 25–27)
The High Court reiterated that revisional jurisdiction is not appellate in character. It is confined to correcting jurisdictional error, patent illegality, or material irregularity. Since the Juvenile Justice Board acted strictly in accordance with Section 94 and binding precedent, no ground for interference was made out.
Ratio Decidendi: Revisional powers under Sections 397 and 401 Cr.P.C. cannot be exercised to substitute findings of fact properly arrived at by the Juvenile Justice Board unless patent illegality or perversity is demonstrated.
Final Disposition
The Criminal Revision Case was dismissed. The order dated 04.07.2025 passed by the Principal Magistrate, Juvenile Justice Board, Anantapuramu, declaring Respondent Nos. 2 and 3 as juveniles in conflict with law, was upheld. No order as to costs. Pending interlocutory applications stood closed.
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