Juvenility under JJ Act: Private Documents Not Conclusive Proof of Age, says SC

The Supreme Court ruled on juvenility under JJ Act, holding that private school records alone are not conclusive proof of age. In Suresh vs. The State of Uttar Pradesh  delivered 1 August 2025, the Court found that private school records of transfer based on oral statements were unreliable when contrary evidence of more credible nature exists. 

The bar of Section 12 in The Juvenile Justice (Care And Protection Of Children) Rules, 2007 is not rigid. The documentary evidence needs to be verifiable and credible. However in cases of grave and heinous offence with conflicting evidence regarding age, medical opinion or documents of public character would take precedence. In this case the Court relied primarily on the doctor’s estimation of age which is a stronger substance of proof due to its emphasis on scientific methodology. The entry in the Voter’s List of U.P. Panchayat Raj Act, 1947 disclosed the age of the accused to be about 22 years of age. 

A bench of Justices Pankaj Mithal and Ahsanuddin Amanulla maintained its balancing act by reaffirming the ratio in Om Prakash v. State of Rajasthan. The Statute does not permit the accused to commit a grave offence and take statutory shield under the guise of being a minor. When there happens to be reasonable doubt about assertion of minority, due weight needs to be given to scientific investigation to determine authenticity and ulterior motives. 

The conduct and manner of commission of crime can also shed light on the matured skill of the accused rather than a child. The Juvenile Justice is a benevolent legislation meant for minors without the matured mind who wants to use the plea as a ploy against the course of justice.

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