In a groundbreaking decision, the Supreme Court has acquitted a woman who had been sentenced to life imprisonment for a murder committed in 2000, asserting that she was a juvenile at the time of the offence. The Bench of Justices Abhay Oka and Ujjal Bhuyan set aside the decisions of both the High Court and the Trial Court, emphasizing that the accused’s age during the occurrence of the offence fell under the purview of the Juvenile Justice Act.
Background of the Case
Pramila, the accused, was initially convicted for murder in 2000 and sentenced to life imprisonment by the trial court. The High Court upheld the sentence on appeal, leading Pramila to file a criminal appeal before the Supreme Court. During the appeal hearing, Pramila asserted her juvenility at the time of the offence.
The Supreme Court, after a meticulous examination of documents verifying Pramila’s date of birth, conclusively determined that she was indeed a juvenile at the time of the offence. Notably, the court applied the Juvenile Justice Act of 1986, as the incident predated the enactment of the Juvenile Justice (Care and Protection of Children) Act, 2000. The court highlighted that, according to the 1986 Act, a juvenile girl is defined as someone who has not attained the age of eighteen years.
The court noted the glaring discrepancy in sentencing, as the maximum punishment under the Juvenile Justice Act was sending the accused to a special home for up to three years. Given that Pramila had already undergone more than eight years of incarceration as a juvenile, the court deemed the imposition of a life sentence unjustified.
“In the case of a girl of sixteen years of age, she could have been sent to a special home for a period of not less than three years. As per Section 22(1) of the 1986 JJ Act, there was a prohibition on sentencing a juvenile to undergo imprisonment,” the court emphasized.
Taking into account the eight-year incarceration already served by Pramila, the Supreme Court ruled in favor of her acquittal. The court stated that the judgments of the High Court and the Additional Sessions Judge, pertaining to Pramila, were quashed and set aside.
“Hence, the present Appeal must succeed, and the impugned judgment and order dated 3rd May, 2010, passed by the High Court and the impugned judgment and order dated 30th June, 2003, passed by the Additional Sessions Judge, Ramanujganj, District Sarguja, Chhattisgarh, are hereby quashed and set aside only insofar as the appellant (accused no.2) is concerned,” the court concluded in the operative part of the order.
In conclusion, this landmark decision not only upholds the rights of a juvenile offender but also sheds light on the need for careful consideration of age during the commission of an offence. The court’s emphasis on the appropriate sentencing under the Juvenile Justice Act marks a significant legal precedent, reaffirming the importance of fair and just proceedings.