Case Title: Manoj @ Monu @ Vishal Chaudhary  Vs. State of Haryana & Anr

Decided On: FEBRUARY 15, 2022, NEW DELHI


Welcome to the official blog of the Law Offices of Kr. Vivek Tanwar Advocate and Associates, where we are dedicated to providing litigation support services for matters related to the Juvenile Justice Act. In today’s blog post, we aim to shed light on the prevailing issues surrounding the Juvenile Justice Act, the legal framework for their protection, and the steps we can take as a society to combat these acts. Join us as we explore this critical subject and empower you with the knowledge to protect your rights and safety.

In a significant legal pronouncement, the Supreme Court of India has asserted that the use of unreliable or dubious documents to claim juvenility in criminal cases is unacceptable. The ruling emphasizes the need for a genuine and truthful presentation of the plea of juvenility under the Juvenile Justice Act, given the act’s beneficial nature. A Division Bench comprising Justice Hemant Gupta and Justice V. Ramasubramanian delivered this verdict.

Background of the Case

The case revolves around an individual named Manoj (Appellant), accused in a 2011 incident. The allegation against Manoj was that he intercepted a car and robbed the occupants of Rs. 22 lakhs. Tragically, one of the car’s occupants, Bhim Singh, lost his life due to a gunshot during the incident. In the course of the trial, Manoj submitted an application claiming that he was a juvenile at the time of the incident, citing his school records as evidence.

The Additional Sessions Judge accepted this plea and declared Manoj a juvenile based on an Ossification Test report that stated he was 16 years, 8 months, and 5 days old at the time of the occurrence. On appeal, the High Court relied on the family register prepared under The U.P. Panchayat Raj (Maintenance of Family Register) Rules, 1970, and rejected the plea of juvenility. This led to the current appeal before the Supreme Court.

The Supreme Court’s Findings

The Supreme Court, after careful examination of the case, found that the presented date of birth certificate appeared to be arranged specifically to claim the benefits offered by the Juvenile Justice (Care and Protection of Children) Act, 2000. Consequently, the date of birth certificate produced by the appellant was considered unreliable because it had been obtained after the application under Section 7A of the Act was filed.

The Court further noted that the ossification test, which was used for age determination, couldn’t establish a consistent standard due to variations influenced by climatic, dietary, hereditary, and other factors that vary among people from different Indian states.

Justice Gupta, speaking on behalf of the Bench, underscored that Rule 12(3) of the Juvenile Justice (Care and Protection of Children) Rules, 2007, specifies that birth certificates issued by a corporation, municipal authority, or panchayat are relevant documents to prove juvenility, whereas the family register is not considered a birth certificate.

In light of these findings, the Supreme Court concluded that the appellant had approached the Court with documents that lacked authenticity and trustworthiness, leading to the denial of the benefit of juvenility.

This ruling underscores the importance of adhering to truthful and reliable documentation when claiming juvenility under the Juvenile Justice Act, ensuring the integrity of the legal process.


Concluding the case, the Supreme Court asserted that the appellant’s reliance on unreliable and untrustworthy documents demonstrated an attempt to approach the Court with unclean hands. Therefore, the benefit of juvenility was denied to the appellant, underscoring the importance of raising such claims in an honest and bona fide manner in the pursuit of justice.

We are a law firm in the name and style of Law Offices of Kr. Vivek Tanwar Advocate and Associates at Gurugram and Rewari. We are providing litigation support services for matters related to the Juvenile Justice Act.

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