Claim of juvenility is unsustainable where continuing offences persist beyond the offender attaining the age of majority.

The revision petitioner was charged under Sections 64(2), 64(2)(M), 89, 115(2), and 351(3) of the Bharatiya Nyaya Sanhita (BNS), 2023; Sections 5L/6 and 5(J)(ii)/6 of the POCSO Act, 2012; and Sections 3/5 of the M.P. Freedom of Religion Act, 2021.

The prosecution alleged that the petitioner, concealing his religious identity, repeatedly sexually assaulted the child victim starting on 23.03.2025, resulting in her pregnancy and its subsequent forced termination.

The petitioner claimed a date of birth of 30.04.2007, asserting he was a "Child in Conflict with Law" (17 years and 10 months old) at the time of the initial incident.

However, the trial court found that the victim's statements recorded under Section 183 of the BNSS indicated the offences, including threats and pressure for religious conversion, continued until 03.06.2025 and 07.08.2025.

The trial court rejected the claim of juvenility, leading to this revision petition.

The court primarily applied Section 2(12) and 2(13) of the Juvenile Justice (Care and Protection of Children) Act, 2015, which defines a "child" and "child in conflict with law" as a person who has not completed eighteen years of age on the date of the offence.

It relied on the precedent established in Vikas Chaudhary v. State (NCT of Delhi) and Another (2010) 8 SCC 508, which holds that in the case of a "continuing offence," the relevant date for determining juvenility is the date on which the last act of the offence was committed.

The Court observed that while the petitioner's date of birth (30.04.2007) was accepted, the nature of the crime was not a single isolated act but a series of continuous incidents.

The Court noted that the penetrative sexual assaults, forced termination of pregnancy, and subsequent threats for religious conversion formed a continuous chain of events.

Applying the doctrine of continuing offences from Vikas Chaudhary, the Court reasoned that the first incident of 23.03.2025 could not be segregated from subsequent acts occurring on 03.06.2025 and 07.08.2025.

Since the petitioner attained majority on 30.04.2025 and continued to commit the alleged offences thereafter, the Juvenile Justice Act ceased to be applicable.

Since the petitioner continued the criminal acts well after attaining the age of 18, the trial court's order rejecting the claim of juvenility was found to be just and proper.

The Criminal Revision was dismissed, and the petitioner shall be tried as an adult.