Child In Conflic With Law vs Staet Of M P

NEUTRAL CITATION NO. 2026:MPHC-IND:30355
1 CRR-4376-2026
IN THE HIGH COURT OF MADHYA PRADESH
AT INDORE

BEFORE
HON'BLE SHRI JUSTICE ALOK AWASTHI
rd
ON THE 23 OF OCTOBER, 2026
CRIMINAL REVISION No. 4376 of 2026
CNR No.: MPHC020390232026
CHILD IN CONFLICT WITH LAW
Versus
STATE OF M P
Appearance:
Shri Ritu Raj Bhatnagar, Advocate for the applicant.
Ms. Usha Chouhan, Government Advocate for the respondent/State.
ORDER
This criminal revision under Section 102 of the Juvenile Justice (Care and
Protection of Children) Act, 2015 (for short “JJ Act”) has been preferred by the Child
in Conflict with Law “E” against the order dated 02.07.2026 passed by the Special
Judge/6th Additional Sessions Judge/Juvenile Court, Ratlam in Criminal Appeal
No.146/2026, whereby the order dated 23.06.2026 passed by the Principal Magistrate,
Juvenile Justice Board, Ratlam rejecting the application under Section 12 of the JJ Act
has been affirmed.
2. The applicant (Child in Conflict with Law “E”, aged about 17 years) is facing
inquiry in Crime No.254/2026 registered at Police Station Alote, District Ratlam for the
offences punishable under Sections 103(1) and 3(5) of the Bharatiya Nyaya Sanhita,
2023. He was produced before the Juvenile Justice Board on 22.05.2026 and has been
kept in the Observation Home, Ratlam since then.
3. As per the prosecution case, on 19.05.2026 at about 8:30 PM, deceased
Krishnapal allegedly informed that Kuldeep Singh, the present applicant (Child “E”),
Yuvraj Singh and another Child in Conflict with Law “GO” had forcibly administered
Signature Not Verified
Signed by: GEETA PRAMOD
Signing time: 29-10-2026
18:35:43

NEUTRAL CITATION NO. 2026:MPHC-IND:30355
2 CRR-4376-2026
some drug/substance into his mouth and left him under the bridge on Khedi Road –

Dharola Bypass. The deceased was taken to hospital where he succumbed during
treatment. The incident is said to have occurred after a prior quarrel in a fair over
spitting of gutkha.
4. The application under Section 12 of the JJ Act for release on bail/supurdagi
was rejected by the Juvenile Justice Board on 23.06.2026. The appeal preferred under
Section 101 of the JJ Act was dismissed by the Juvenile Court on 02.07.2026 mainly
on the ground of seriousness of the offence and the possibility of the child coming into
contact with known criminals or the ends of justice being defeated.
5. Learned counsel for the applicant submitted that the applicant is a juvenile
with no criminal antecedents. The Social Investigation Report indicates that he lives
with his parents, is studying, and there is every possibility of reformation under proper
parental care. The Courts below have rejected bail solely on the gravity of the offence
without recording any specific material attracting the exceptions carved out in the
proviso to Section 12 of the JJ Act. He prayed for release of the child in the custody of
his natural guardian (father).
6. Learned counsel for the State opposed the revision and supported the
impugned orders, contending that the offence is serious in nature and release of the
child may defeat the ends of justice.
7. I have considered the rival submissions and perused the record, including the
Social Investigation Report.
8. Section 12 of the JJ Act mandates that a child alleged to be in conflict with
law shall be released on bail with or without surety or placed under the supervision of a
probation officer or under the care of any fit person, notwithstanding anything
contained in the Code of Criminal Procedure or any other law. The only exceptions
are:-
(i) if there appear reasonable grounds for believing that the release is likely to
Signature Not Verified
Signed by: GEETA PRAMOD
Signing time: 29-10-2026
18:35:43

NEUTRAL CITATION NO. 2026:MPHC-IND:30355
3 CRR-4376-2026
bring the child into association with any known criminal; or

(ii) expose the child to moral, physical or psychological danger; or
(iii) the release would defeat the ends of justice.
The Board is required to record specific reasons for denying bail.
9. In the present case, the Social Investigation Report does not indicate any
previous criminal antecedents. The child belongs to a normal family; his father is an
agriculturist and mother a housewife. The report suggests that the possibility of
improvement under proper family supervision cannot be ruled out. No specific material
has been brought on record by the prosecution to show that release of the child would
bring him into association with known criminals or expose him to moral, physical or
psychological danger, or that his release would defeat the ends of justice. Gravity of the
offence by itself is not a sufficient ground to deny the benefit of Section 12 of the JJ
Act.
10. In view of the above, the impugned orders dated 23.06.2026 passed by the
Juvenile Justice Board, Ratlam and dated 02.07.2026 passed by the Juvenile Court,
Ratlam cannot be sustained.
11. The criminal revision is allowed. The impugned orders are set aside.
12. It is directed that the Child in Conflict with Law “E” shall be released and
handed over to the custody of his natural guardian(father) on the father furnishing a
personal bond of Rs.50,000/- (Rupees Fifty Thousand only) with one solvent surety of
the like amount to the satisfaction of the Juvenile Justice Board, Ratlam, subject to the
following conditions:-
(i) The child and his guardian shall cooperate with the inquiry/trial;
(ii) The child shall not indulge in any act of inducement, threat or promise to any
person acquainted with the facts of the case;
(iii) The child shall not commit any offence similar to the one of which he is
accused;
Signature Not Verified
Signed by: GEETA PRAMOD
Signing time: 29-10-2026
18:35:43

NEUTRAL CITATION NO. 2026:MPHC-IND:30355
4 CRR-4376-2026
(iv) The child shall not seek unnecessary adjournments;

(v) During the period of bail, the child shall remain under the supervision and
control of his father, who shall be responsible for his maintenance, well-being and
overall activities;
(vi) The father shall give an undertaking that the child will not be permitted to
come into contact or association with any known criminal or be exposed to any moral,
physical or psychological danger, and that he will ensure that the child does not repeat
the offence;
(vii) The child shall report to the Probation Officer on the last date of every
calendar month. The Probation Officer shall keep a strict vigil on the activities of the
child and submit periodical Social Investigation Reports to the Juvenile Justice Board
as and when required;
(viii) The father shall ensure the appearance of the child before the Juvenile
Justice Board on all dates fixed till final disposal of the inquiry.
13. With the aforesaid, present revision is allowed and stands disposed of.
14. A copy of this order be sent to the Juvenile Justice Board, Ratlam and the
Observation Home, Ratlam for information and necessary compliance.
Certified copy, as per Rules.
(ALOK AWASTHI)
JUDGE
gp
Signature Not Verified
Signed by: GEETA PRAMOD
Signing time: 29-10-2026
18:35:43