Sanjay Singh v. State of Madhya Pradesh, (2022) 3 MPC 696

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FACTS OF THE CASE

• On July 30, 1999, the victim went to fetch water from a well. The appellants allegedly surrounded him. Appellant No. 3 had a gun and a knife, Appellant No. 1 was in possession of a homemade pistol and a sword, and Appellant No. 2 had a pistol and a knife.
• Subsequently, Appellant No. 1 beheaded the victim, and the Appellant No. 2 and 3, stabbed him in the chest and abdomen, resulting in the victim’s immediate death. Another victim was also present and was similarly killed by the appellants, who used firearms, swords, pistols, and knives in the attack. Several witnesses were at the scene.
• This case is a criminal appeal filed against the judgment and sentence passed by the Additional Sessions Judge. The appellants were convicted for the following offenses:  Appellants were convicted under Section 302 of the Indian Penal Code (IPC) and under Sections 25(1)(a) and 27 of the Arms Act.
• During the pendency of the appeal, Appellant No. 3 died, and his appeal was dismissed as abated.

ISSUES: The issues set forth by the court included:

1. Whether the deaths of victims were homicidal in nature?
2. Whether appellant No. 2 was a minor on the date of the incident?

ARGUMENTS

• It was contended that appellant No. 2 was below the age of 18 years on the date of the incident, and though not a juvenile in accordance with the Juvenile Justice Act, 1986, as per the Juvenile Justice Act, 2000, he should be considered a minor.
• The prosecution argued that the evidence supported the conviction of the appellants for the crimes.

JUDGEMENT

• The court found that the deaths of victims were homicidal in nature based on the medical evidence presented in the post-mortem reports.
• The court determined that appellant No. 2 was indeed a minor on the date of the incident. Despite not qualifying as a juvenile under the Juvenile Justice Act, of 1986 (where the age limit was 16 years), he should be treated as a minor under the Juvenile Justice Act, of 2000, which raised the age limit to 18 years for juveniles.
• The court relied upon the judgment in Pratap Singh v. State of Jharkhand, in which it was held that the Juvenile Justice (Care and Protection of Children) Act, 2000 would be applicable to any pending legal proceeding initiated under the Juvenile Justice Act, 1986 in any court or authority, provided that the individual had not attained the age of eighteen years on April 1, 2001, when the 2000 Act became effective.  
• Thus, Appellant No. 1 was sentenced to life imprisonment for the murder charges. The sentence of appellant No. 2 was set aside, and the case was remitted to the Juvenile Justice Board (JJB) for determining an appropriate fine.
• Thus, the appeal by Appellant No. 1 Sanjay Singh was dismissed.

ANALYSIS

The Juvenile Justice Act’s main goal is to care for, protect, treat, develop, and rehabilitate neglected and delinquent juveniles. Legal interpretation should favor the legislation’s objectives when it benefits the intended group, rather than hindering the legislative intent.

REFERENCES

1. https://indiankanoon.org/doc/114059777/
2. https://mphc.gov.in/upload/gwalior/MPHCGWL/2011/CRA/696/CRA_696_2011_Judgement_22-Jun-2022.pdf

This Article is written by Anuja Malai of Raja Lakhamgouda Law College, Intern at Legal Vidhiya

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