“Documentary Primacy & Finality” – Commentary on Rajni v. State of Uttar Pradesh, 2025 INSC 737

1. Introduction

Rajni v. State of Uttar Pradesh presented the Supreme Court with two intertwined questions:

1. Was the accused (Respondent No.2) a juvenile on the date of an alleged murder (17-02-2021)?
2. Was the High Court justified in granting him bail after declaring him a juvenile?

The mother of the deceased (Rajni) challenged (i) a High Court order that relied on school certificates to fix the accused’s date of birth at 08-09-2003, thereby making him 17 years old at the time of the offence, and (ii) a subsequent order granting him bail. Central to the controversy was the correct application of Section 94 of the Juvenile Justice (Care and Protection of Children) Act, 2015 (JJ Act 2015) and the power (or lack thereof) of a Juvenile Justice Board (JJB) to revisit an earlier age-determination decision.

2. Summary of the Judgment

• The Court affirmed the High Court’s finding that documentary evidence (school and municipal birth certificates) must prevail over medical opinion when available, as mandated by s.94(2) JJ Act 2015.
• It held that a JJB cannot review or contradict its own earlier decision on a child’s age; the Act confers no review power.
• It upheld a separate JJB order that had already conducted a preliminary assessment under s.15 (for heinous offences by 16-18-year-olds) and transferred the matter to the Children’s Court.
• While agreeing the High Court erred in certain observations on bail, the Court declined to cancel bail because the accused had been free for three years without misuse.
• Both criminal appeals filed by the informant were dismissed.

3. Analysis

3.1 Precedents Cited & Their Influence

1. Rishipal Singh Solanki v. State of U.P. (2022) 8 SCC 602
   Reiterated that documents under Rule 12 JJ Rules 2007 / s.94(2) JJ Act 2015 create a prima facie presumption of age; ossification is a last resort. The Court heavily relied on paragraphs 33.1-33.11 to reaffirm documentary primacy.
2. P. Yuvaprakash v. State, 2023 INSC 676
   Emphasised that a transfer certificate alone may not satisfy s.94(2)(i) and that prosecution bears the burden of producing primary documents. The Court distinguished the present facts by noting that valid high-school and municipal certificates did exist, satisfying s.94(2)(i)-(ii).
3. Union Territory of J&K v. Shubam Sangra, 2022 INSC 1205
   Allowed medical opinion where documents were suspicious. The present Bench distinguished it, stating that here documents were authentic and previously accepted by the very same JJB, leaving no room for medical tests.

3.2 Legal Reasoning

Key Ratio: Where authentic school/municipal birth records exist, the JJB is statutorily barred from ordering medical age tests; doing so amounts to jurisdictional error and impermissible review of its earlier order.

The Court’s reasoning flowed in four logical steps:

1. Statutory Hierarchy (s.94 JJ Act 2015) – Documentary evidence (school certificate → municipal certificate) enjoys priority; only in their absence can medical testing be invoked.
2. No Power of Review – The JJB had previously accepted 08-09-2003 as the date of birth in Misc. Case 9/2000. Revisiting that finding in 2021 amounted to an impermissible review.
3. Preliminary Assessment Requirement – Since the accused was between 16-18 and charged with a “heinous offence”, the JJB correctly conducted s.15 assessment and transferred the file. This demonstrates how juvenility does not automatically shield an accused from adult-like trial.
4. Bail Discretion – Although the Court acknowledged gravity, it applied the settled principle that bail orders untainted by misuse over a long period are rarely disturbed. It left room for cancellation if the accused misbehaves.

3.3 Potential Impact

• Restricts Medical Age Tests: Medical boards may now be approached only after a positive finding that both categories of documents are absent or unreliable. Trial courts and JJBs must record specific reasons before bypassing documentary proof.
• Finality of JJB Orders: JJBs cannot “undo” their own age-determination orders in subsequent cases unless set aside by a higher forum. This insulates juveniles from inconsistent findings and forum shopping.
• Section 15 Road-Map Clarified: Even after being declared juvenile, children aged 16-18 accused of heinous offences may still face transfer to Children’s Courts after preliminary assessment—balancing rehabilitative and societal interests.
• Bail Jurisprudence: Bail granted to juveniles can remain undisturbed if no post-release misconduct is shown, signalling deference to rehabilitation.

4. Complex Concepts Simplified

Juvenile Justice Board (JJB)

A specialised quasi-judicial body that handles cases involving children in conflict with law, up to preliminary assessment.

Section 94 JJ Act 2015

Lays down a three-tiered test for determining age: (i) school/board certificates, (ii) municipal/panchayat certificate, (iii) medical tests – in that order.

Ossification Test

A radiological examination of bone fusion used to estimate age; widely considered approximate (±2 years).

Heinous Offence

Any crime where the minimum statutory sentence is seven years or more (e.g., murder, rape).

Preliminary Assessment (s.15)

An inquiry, not a trial, to evaluate a juvenile’s mental/physical capacity, understanding of consequences, and circumstances to decide if he should be tried as an adult.

Children’s Court

A designated Sessions Court empowered to try heinous offences by children when directed under s.18(3).

5. Conclusion

Rajni v. State of Uttar Pradesh cements two crucial propositions:

1. Documentary Primacy: Authentic school and municipal birth records enjoy precedence; medical age testing is a last resort.
2. Jurisdictional Finality: A JJB cannot revisit its earlier age-determination; any challenge must travel to appellate or revisional fora.

By reinforcing these principles, the Supreme Court bolsters certainty in juvenile proceedings, curtails unnecessary medical examinations, and preserves rehabilitative ideals without compromising societal safety where heinous crimes are involved. Courts, investigators, and defence counsel alike must now meticulously secure and scrutinise documentary age proof at the earliest stage to avoid procedural missteps.