Facts
The Appellant, a Child in Conflict with Law (CICL), challenged an order dated 07.08.2025 passed by the Children’s Court-cum-Addl. Sessions Judge-I, Balangir, which refused his bail application
Source reference: p. 1The Appellant was allegedly involved in the murder of Shyam Sundar Bag and the assault of the deceased’s wife and parents using deadly weapons like axes and spades
Source reference: p. 1-2The FIR named the CICL alongside four adult co-accused persons
Source reference: p. 6The appellant argued that the offence was a result of environmental influence and immaturity, noting he had been in an observation home for one year
Source reference: p. 2Issues
Whether the Appellant/CICL is entitled to bail under the statutory framework of the Juvenile Justice (Care & Protection of Children) Act, 2015, despite the gravity of the alleged offences
Source reference: p. 3Law Applied
Section 12 of the Juvenile Justice (Care & Protection of Children) Act, 2015, which mandates that a CICL shall be released on bail notwithstanding the Code of Criminal Procedure, unless there are reasonable grounds to believe that the release would bring the child into association with known criminals, expose them to moral, physical, or psychological danger, or otherwise defeat the ends of justice
Source reference: p. 3-4Reasoning
The Court observed that while bail is the rule and detention an exception for a CICL, the specific exceptions under Section 12 were triggered in this case
Source reference: p. 4The Court examined the Psychological Assessment Report, which noted the CICL possessed the physical and mental capacity to plan and execute the offence and was aware of the legal consequences
Source reference: p. 5The Social Investigation Report (SIR) highlighted "parental neglect" and "peer group influence," suggesting the CICL required intensive counseling to change "wicked intentions"
Source reference: p. 5-6The Court placed significant weight on the fact that the CICL acted in association with four adult co-accused to commit a brutal murder involving 14 external injuries
Source reference: p. 6The Court reasoned that releasing the CICL would likely bring him into further association with criminals and defeat the ends of justice
Source reference: p. 6-7Holding
The Court answered the issue in the negative, holding that the Appellant failed to satisfy the criteria for bail under Section 12 of the Act
The High Court upheld the lower court's decision, rejected the prayer for bail, and dismissed the Criminal Appeal
Source reference: p. 7Original Court PDF
RANJAN RANAvsSTATE OF ODISHA
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