Pramila vs. State of Chhattisgarh
Citation: 2024 INSC 50; Bench: Justice Abhay S. Oka
Background
Pramila was convicted by the trial court for offences under Sections 302 (murder) and 201 read with Section 34 of the Indian Penal Code, 1860, and sentenced to life imprisonment for her alleged involvement in a murder case dating back to the year 2000. The conviction was upheld by the Chhattisgarh High Court. Pramila appealed to the Supreme Court, raising a crucial plea of juvenility, asserting that she was less than 18 years old at the time of the offence.
Supreme Court’s Analysis
Plea of Juvenility:
The Supreme Court examined whether Pramila was a juvenile on the date of the incident. The Court emphasized that under the Juvenile Justice Act, a claim of juvenility can be raised at any stage, even after conviction and sentencing. The Court scrutinized the evidence, including school records and testimonies, which established that Pramila was below 18 years of age at the time of the offence.
Legal Consequences of Juvenility:
The Court referred to Section 22(1) of the Juvenile Justice Act, 1986, and Section 16 of the Juvenile Justice (Care and Protection of Children) Act, 2000, both of which prohibit sentencing a juvenile to imprisonment for any offence, including murder. The maximum permissible action would have been to send her to a special home for a period not exceeding three years.
Incarceration Already Undergone:
The Court noted that Pramila had already undergone more than eight years of incarceration, which far exceeded the maximum period a juvenile could be confined in a special home. It held that no purpose would be served by sending her to the Juvenile Justice Board at this stage.
Setting Aside Conviction:
In light of the above findings, the Supreme Court allowed the appeal, set aside the conviction and sentence, and ordered Pramila’s release. The Court quashed the impugned judgments of the High Court and the trial court, recognizing her right to benefit from the special provisions for juveniles.
Significance
This judgment reaffirms the principle that a plea of juvenility can be raised at any stage, including after conviction, and that juveniles cannot be sentenced to imprisonment even for serious offences like murder. It underscores the Supreme Court’s commitment to upholding the protective framework of juvenile justice in India.
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