Bail for juvenile cannot be denied if rehabilitation reports show improved conduct and successful drug de-addiction.

The revision petitioner, a "Child in Conflict with Law" (CICL), was implicated in Crime No. 549/2025 at Police Station Neelganga, Ujjain, under Sections 109(1), 115(2), 296(b), 351(3), and 3(5) of the Bharatiya Nyaya Sanhita (BNS), 2023.

The prosecution alleged that the CICL, along with an adult and another juvenile, assaulted individuals attempting to intervene during an attempted murder.

The Juvenile Justice Board (JJB) rejected the bail application on January 28, 2026, citing the CICL's drug addiction and the risk of moral/psychological danger through association with adult criminals.

This order was upheld by the Children's Court on March 9, 2026.

The petitioner challenged these orders via criminal revision under Section 102 of the JJ Act, 2015.

1. Whether the lower courts erred in denying bail to the Child in Conflict with Law under Section 12 of the Juvenile Justice (Care and Protection of Children) Act, 2015, despite subsequent positive reports regarding his de-addiction and conduct.

The Court primarily applied Section 12 of the Juvenile Justice (Care and Protection of Children) Act, 2015, which mandates that a juvenile shall be released on bail unless there are reasonable grounds to believe that the release would bring the person into association with known criminals or expose them to moral, physical, or psychological danger.

The Court considered Section 102 of the same Act regarding the High Court's revisional powers to check the legality and propriety of orders passed by the JJB or Children's Court.

The Court analyzed reports from the Parivartan De-addiction Centre, the Superintendent of the Special Home, Indore, and the Observation Home, Ujjain, which showed the CICL was admitted to de-addiction on January 23, 2026, and discharged on January 27, 2026, following significant improvement.

Although the child attained the age of 18 on January 26, 2026, and was moved to a "place of safety," recent reports dated April 28, 2026, confirmed his conduct and mental health were positive.

The Court found that the initial grounds for refusal—namely addiction and the risk of bad association—were mitigated by the successful rehabilitation and the favorable reports from the authorities.

The Court determined that the statutory requirements for granting bail under the JJ Act were met.

The release was conditioned upon a personal bond of Rs. 50,000/- with one solvent surety; the Court further ordered the guardian to ensure the minor avoids criminal associations and directed the Probation Officer to maintain periodic vigilance.