A juvenile’s bail may be denied only on Section 12’s specified, evidence-based grounds.

The four appellants, children in conflict with law (CICLs), appealed against separate orders dated 17 February 2026 of the Children Court, Siwan, refusing them bail under Section 12 of the Juvenile Justice (Care and Protection of Children) Act, 2015, in connection with Basantpur P.S. Case No. 485 of 2025.

The prosecution alleged that the appellants and a co-accused killed the informant’s 18-year-old son and attempted to burn his body to destroy evidence; the case was based on circumstantial evidence, with no alleged eyewitness.

The Children Court refused bail on the view that release could expose the appellants to danger and defeat the ends of justice, relying on the Social Investigation Report.

1. Whether the Children Court’s refusal of bail was sustainable under Section 12 of the Juvenile Justice Act, 2015, in the absence of material supporting any of the statutory grounds for refusal.

2. Whether the seriousness of the alleged offence or the appellants’ age could, by itself, justify refusing bail to a juvenile in conflict with law.

Section 12(1) of the Juvenile Justice Act, 2015, provides that a child alleged to be in conflict with law is to be released on bail, with or without surety, or placed under supervision or the care of a fit person.

Bail may be refused only where there are reasonable grounds to believe that release would bring the child into association with a known criminal, expose the child to moral, physical or psychological danger, or defeat the ends of justice; the reasons and supporting circumstances must be recorded.

The Court relied on Juvenile in Conflict with Law v. State of Rajasthan, Re: Exploitation of Children in Orphanages in the State of T.N. v. Union of India, and decisions of various High Courts for the principles that the statutory exceptions must be specifically supported by material and that the offence’s gravity is not, by itself, a ground to deny bail.

It further considered Sections 3 and 15(2) of the Act, including the principles of the child’s best interests, family responsibility, institutionalisation as a last resort, and the relevance of the Social Investigation Report.

The High Court examined the Children Court’s orders and the Social Investigation Reports.

Although the Children Court had inferred that the appellants’ release might expose them to danger and defeat the ends of justice, the reports did not show that they had been in contact with known criminals, had been neglected by their parents, or would face moral, physical or psychological danger if released.

The Court held that the Children Court’s conclusion on the ends of justice was misconceived: under the Act, that ground must be assessed in light of the child’s welfare, development and rehabilitation, and cannot rest solely on the heinous nature of the alleged offence.

As the statutory grounds for refusing bail were not established by the material, the refusal was unsustainable.

It directed the appellants’ release on bail on bonds of ₹10,000 each, subject to undertakings by their respective fathers to supervise their habits, prevent contact with criminal persons, attend to their developmental needs, ensure that they continue their studies, and secure their attendance before the Court when required.