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).
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).