A juvenile must be granted bail unless Section 12’s exceptional grounds for refusal are established.

The juvenile petitioner challenged the Sessions Judge, Guna’s order affirming the Juvenile Justice Board’s rejection of his bail application in a case registered under Sections 64(1) and 108 of the Bharatiya Nyaya Sanhita, 2023.

He had been in custody since 22 August 2026.

The defence relied on the Probation Officer’s report, which recorded the petitioner’s account of his relationship with the deceased and was described as positive; it also submitted that the petitioner had no criminal antecedents and that no statutory ground for denying bail was established.

The High Court considered the case diary, the orders below, and the Probation Officer’s report.

1. Whether the juvenile petitioner was entitled to bail under Section 12 of the Juvenile Justice (Care and Protection of Children) Act, 2015, notwithstanding the rejection of bail by the courts below.

2. Whether any of the exceptional grounds in the proviso to Section 12 justified withholding the petitioner’s release.

Section 12(1) of the Juvenile Justice (Care and Protection of Children) Act, 2015 provides that a person who is apparently a child and is alleged to have committed an offence shall ordinarily be released on bail, with or without surety, or placed under the supervision of a probation officer or the care of a fit person.

Bail may be denied only where reasonable grounds indicate that release is likely to bring the child into association with a known criminal, expose the child to moral, physical, or psychological danger, or defeat the ends of justice; reasons for denial must be recorded.

Section 102 of the Act provides the basis for the criminal revision.

No precedent was cited.

The Court noted that the petitioner was a minor on the alleged date of the incident and assessed the orders below against Section 12 and the Probation Officer’s report.

It found no exceptional circumstance under the statutory proviso to justify refusing bail.

Accordingly, the ordinary rule favouring release of a child alleged to be in conflict with law applied.

The High Court set aside the Sessions Judge’s order dated 15 September 2026 and the Juvenile Justice Board’s order dated 9 September 2026, and directed that the petitioner be handed over to his father upon furnishing a personal bond of ₹50,000 and one solvent surety to the satisfaction of the Board or Court, Guna.

The petitioner must appear when directed, and his guardian must care for him and keep him away from known criminals; the petitioner must not become involved in another offence during the trial.