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Rajasthan High Court
Criminal Law

Juvenile Convicted of Murder: Children's Court Must Give Reasons for Fixed-Term Sentence, Rajasthan High Court Holds

On a State appeal against sentence, the Rajasthan High Court held that Section 21 of the Juvenile Justice Act bars only death and life imprisonment without the possibility of release for a child in conflict with law, so life imprisonment with the possibility of release remains available. The Children's Court had imposed ten years' rigorous imprisonment for murder without giving any reason, so the sentence was set aside and the matter remanded for fresh sentencing (paras 6-7).

Juvenile Convicted of Murder: Children's Court Must Give Reasons for Fixed-Term Sentence, Rajasthan High Court Holds

Judgment Intelligence

Petition Allowed
State of Rajasthan v. Juvenile in Conflict with Law "A"
2026:RJ-JP:39558-DB
D.B. Criminal Appeal No. 297/2026
Court
Rajasthan High Court
Date of Decision
29 September 2026
Bench
Justices Mahendar Kumar Goyal and Bhuwan Goyal
Relevant Acts & Sections
Juvenile Justice (Care and Protection of Children) Act, 2015 — Section 21; Indian Penal Code, 1860 — Section 302; Arms Act, 1959 — Section 4/25; Bharatiya Nagarik Suraksha Sanhita, 2023 — Section 418
Final Outcome

Appeal allowed. The sentencing order of 11 February 2026 was set aside and the matter remanded to the Children's Court to pass a fresh order on sentence (para 7).

Key holdings

  1. Section 21 of the Juvenile Justice Act bars only the death penalty and life imprisonment without the possibility of release for a child in conflict with law (paras 5-6).
  2. Life imprisonment with the possibility of release remains a permissible sentence (para 6).
  3. A Children's Court must give cogent reasons when it imposes a limited fixed-term sentence for murder (para 6).
  4. An unreasoned sentencing order can be set aside and remitted for fresh sentencing without disturbing the conviction (para 7).

Brief Facts

A child in conflict with law was convicted by the Children's Court (Sessions Judge), Sawai Madhopur under Section 302 IPC and Section 4/25 of the Arms Act, and sentenced to ten years' rigorous imprisonment with a fine of ₹5,000 for murder and one year's rigorous imprisonment for the Arms Act offence (para 1). The State appealed under Section 418 BNSS only against the sentence, contending that no reasons were given for choosing a ten-year term instead of life imprisonment (paras 1-2). Counsel for the juvenile did not dispute the proposition (para 3).

Court's Findings

Section 21 of the Juvenile Justice (Care and Protection of Children) Act, 2015 provides that no child in conflict with law shall be sentenced to death or to life imprisonment without the possibility of release (para 5). The Court read this to mean that "the sentence for life imprisonment can always be awarded provided it is not without the possibility of release" (para 6). It therefore held that the trial court was obliged to furnish cogent reasons for imposing a limited term of ten years (para 6). Since the sentencing order of 11 February 2026 gave no reason for choosing the limited period, it could not stand (para 6). The conviction was not under challenge; only the question of sentence was sent back (paras 1, 7).

Legal Principle

Section 21 of the Juvenile Justice Act, 2015 bars only death and life imprisonment without the possibility of release for a child in conflict with law. A Children's Court sentencing such a child for murder must give cogent reasons for the term it chooses; an unreasoned fixed-term sentence cannot stand (paras 5-7).
Nyay Vidhan
Court Judgments · 2 min read
Decided: September 29, 2026 Justices Mahendar Kumar Goyal and Bhuwan Goyal
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