A juvenile conviction may stand, but sentencing must be determined by the Juvenile Justice Board.

The appellant was convicted under Section 302 IPC and sentenced to life imprisonment for the murder of Ajay Kumar Singh.

The prosecution case rested on circumstantial evidence, including last-seen testimony and the recovery of a blood-stained gandasa and clothing; the trial court acquitted the co-accused but convicted the appellant.

During the appeal, the appellant claimed juvenility, relying on educational records showing his date of birth as 15 November 1981. The State verified those records and did not dispute the date of birth.

The offence occurred on 2 February 1999, when the appellant was 17 years, 2 months and 17 days old.

The appellant did not challenge his conviction, but sought to have the sentence set aside and the matter remitted to the Juvenile Justice Board.

Whether the appellant was a juvenile on the date of the offence, and what evidence governed determination of his age.

Whether, upon accepting the juvenility claim, the High Court should interfere with the conviction or the sentence and refer the matter to the Juvenile Justice Board.

Section 7A of the Juvenile Justice (Care and Protection of Children) Act, 2000 permits a claim of juvenility to be raised at any stage, including after final disposal, and requires the court to determine the claim.

Section 94 of the Juvenile Justice Act, 2015 gives priority to the prescribed documentary evidence, including school or matriculation records, for age determination.

The Court applied the principles discussed in Mumtaz v. State of U.P., (2016) 11 SCC 786: under Section 20 of the 2000 Act, a court may maintain a finding of guilt but, upon finding the person was a juvenile on the offence date, should not impose an ordinary criminal sentence and should instead refer the matter to the Juvenile Justice Board for appropriate orders.

The Court also relied on the cited decisions concerning the effect of Section 20 and the Board’s role in determining the appropriate order.

The verified High School and school-transfer records established the appellant’s date of birth as 15 November 1981; applying Section 94’s documentary-evidence approach, the Court held he was a juvenile when the offence occurred.

The appellant expressly did not contest the conviction. The Court nevertheless considered the evidence, including the last-seen testimony and recovery evidence, and found no perversity or illegality warranting interference with the trial court’s finding of guilt.

Because the appellant was a juvenile on the offence date, the ordinary sentence of life imprisonment could not stand; the appropriate order was for the Juvenile Justice Board to determine the order permissible under the applicable juvenile-justice law.

It set aside the sentence and remitted the matter to the jurisdictional Juvenile Justice Board for appropriate orders in accordance with law.

The appellant, already on bail, was directed to appear before the Board on 27 October 2026; the Board was directed to pass orders within four weeks of receiving a certified copy of the judgment.

The appeal was partly allowed to that extent.