Bail is warranted for a juvenile when prosecution evidence discloses no prima facie case.

The appellant, a juvenile, challenged the order dated 08.01.2025 passed by the District and Additional Sessions Judge-I-cum-Special Judge, Madhepura, in B.P. No. 3012 of 2024, arising from Alamnagar P.S. Case No. 7 of 2024 and Children Case No. 15 of 2024, whereby his regular bail application was rejected.

During the pendency of the trial, five prosecution witnesses, including the alleged victims and their parents, were examined.

According to the appellant, none supported the prosecution case; the alleged victims and their parents stated that no incident had occurred and that the case had been lodged due to a misconception of facts.

The State accepted that deprivation of liberty must be supported by a prima facie case and that liberty cannot be curtailed without sufficient reason.

1. Whether the appellant was entitled to regular bail when the depositions of the alleged victims and their parents did not support the prosecution case.

2. Whether continued deprivation of a juvenile’s liberty under the juvenile justice process could be justified in the absence of a prima facie case against him.

The Court applied the constitutional protection of life and personal liberty, holding that a person’s liberty cannot be curtailed without lawful and sufficient justification.

It further applied the bail principle that continued detention must be supported by a prima facie case and that this requirement also applies to the detention of a juvenile under the juvenile justice framework.

No specific statutory provision or judicial precedent was expressly cited in the judgment.

The Court examined the depositions of the alleged victims and their parents and found that they consistently indicated that nothing had happened on the alleged date of occurrence and that the criminal case had resulted from a misconception of facts.

Since the material witnesses did not support the prosecution case, the Court concluded that no prima facie case remained to justify the appellant’s continued detention.

Applying the principle that liberty cannot be curtailed in the absence of sufficient legal justification, the Court held that the appellant should be released on bail during the pendency of the trial.

His father was required to furnish an affidavit undertaking to supervise the appellant’s habits, prevent his association with criminal persons, attend to his developmental needs, and ensure that he appeared before the Children Court whenever required or directed.

The lower court records were directed to be returned to the concerned court along with a copy of the judgment.