Jharkhand High Court
Criminal LawCriminal Procedure and Evidence

Section 12 Juvenile Justice Act bail provisions apply uniformly, without offence-based classification among juveniles.

KARAN KUMAR vs THE STATE OF JHARKHAND

Jharkhand High CourtJUDGMENT: October 01, 20262 MIN READSOURCE JUDGMENT
Section 12 Juvenile Justice Act bail provisions apply uniformly, without offence-based classification among juveniles.. KARAN KUMAR vs THE STATE OF JHARKHAND. Jharkhand High Court. LawLens
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The revisions arose from Daru P.S. Case No. 20 of 2026, initially registered under Sections 126(2), 115(2), 118(1), 109(1) and 3(5) of the Bharatiya Nyaya Sanhita (BNS); after the injured person died, Section 103(1) was added.

Source reference: para. 3, p. 2

Both petitioners were juveniles, aged about 17 at the time of the incident, and had been in a remand home since 4 April 2026.

Source reference: para. 4, p. 2

The Juvenile Justice Board rejected their bail applications on 22 May 2026, and the appellate court dismissed their appeals on 9 July 2026.

Source reference: para. 3, p. 1

The petitioners challenged those orders.

Source reference: para. 3, p. 1

The State and informant opposed bail, particularly on the basis of the direct allegation that Karan Kumar had stabbed the deceased.

Source reference: para. 5, p. 2
02

Issues

Whether Manish Kumar @ Verma, a juvenile accused in the case, was entitled to bail under Section 12 of the Juvenile Justice (Care and Protection of Children) Act, 2015, notwithstanding the gravity of the alleged offence.

Source reference: paras. 7–9, pp. 3–4

Whether Karan Kumar’s direct implication in the fatal stabbing justified refusing bail and upholding the lower courts’ orders.

Source reference: paras. 5–6, p. 2
03

Law Applied

The Court applied Section 12 of the Juvenile Justice (Care and Protection of Children) Act, 2015, stating that it applies to all juveniles in conflict with law without discrimination and that the provision makes no classification based on the seriousness of the offence.

Source reference: para. 8, p. 3

The Court also considered the case-specific material concerning the accusation against each juvenile, including the deceased’s naming of Karan Kumar as the person who stabbed him.

Source reference: para. 6, p. 3

No precedent was cited.

Source reference: no citation
04

Reasoning

As to Manish Kumar @ Verma, the Court found his case identical to that of adult accused persons who had been granted bail by a Coordinate Bench, and applied its understanding of Section 12 that the seriousness of the alleged offence did not, by itself, preclude a juvenile from bail.

Source reference: paras. 7–8, p. 3

As to Karan Kumar, the Court noted the direct allegation of stabbing and the deceased’s identification of him before death. Given that evidence and the gravity of the offence, it found the appellate court’s reasoning for refusing bail sound.

Source reference: paras. 5–6, p. 2–3
05

Holding

The Court allowed Criminal Revision No. 939 of 2026, set aside the orders refusing Manish Kumar @ Verma bail, and directed his release on bail upon his father furnishing a personal bond and two sureties, subject to undertakings concerning supervision, education and conduct, and monthly reporting to the Probation Officer.

It dismissed Criminal Revision No. 931 of 2026 and refused bail to Karan Kumar.

Source reference: paras. 6, 11, pp. 3, 5
06

Acts & Sections Cited

6 provisions across 2 statutes referred to in this judgment. Each provision opens on LawLens.

Juvenile Justice (Care and Protection of Children) Act, 2015.1

Jharkhand High Court

Original Court PDF

KARAN KUMARvsTHE STATE OF JHARKHAND

Jharkhand High Court · October 01, 2026

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