NATIONAL LAW INSTITUTE UNIVERSITY

BHOPAL

PROJECT
LAW OF CRIMES
SEMESTER-III
TOPIC – CASE ANALYSIS
JAMEEL V. STATE OF MAHARASHTRA

SUBMITTED TO SUBMITTED BY
Prof. Divya Salim Pooja Pandey
2019BALLB124
Enrollment no.- A2166

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CERTIFICATE

This is to certify that the case analysis ‘Jameel v. State of Maharashtra’ has been successfully

prepared and submitted by Pooja Pandey, in fulfilment for requirement of project work

in Semester – III for the subject of Law of Crimes I . It is found that any corrections,

recommendations to be made, have been incorporated in the project. I would like to thank

Prof. Divya Salim for guiding me throughout the project. I would also like to extend my

heartfelt gratitude to the officials at Gyan Mandir.

Prof. Divya Salim

Pooja Pandey

2019BALLB124

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ACKNOWLEDGEMENT

I would like to appreciate the amount of support and guidance given to me by Law of Crimes
Professor, Madam Divya Salim. I would like to thank NLIU’s Library Gyanmandir for its
treasure of resources and research material that I have used in my project. I acknowledge that
without their assistance this project would not have seen its completion.

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TABLE OF CONTENTS

CERTIFICATE 2
ACKNOWLEDGEMENT 3
CHAPTER-1 5
Name of the judgment with full and proper citation 5
Brief background of judgment (Main subject matter of the case) 5
CHAPTER-2 8
Size of the bench 8
Advocates on behalf of both the parties 8
Interveners/Amicus-N/A 8
Material Facts of the case 9
Issues Raised 10
Whether question of fact or law or both 10
Contentions by the appellants 10
Contentions by the respondents 10
About the law/statute/provision 11
Books/Literature/Articles 15
CHAPTER-3 17
CASES REFERRED 17
 Amitsingh Bhikamsing Thakur v. State of Maharashtra 17
 Pratap Singh v. State of Jharkhand and Anr. 18
JUDGEMENT 20
CONCLUSION 22

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CHAPTER-1

NAME OF THE CASE

In the Supreme Court of India

Criminal Appeal No. 173 of 2006

Decided on: 16.01.2007

Jameel v. State of Maharashtra (2007)11 SCC 420

BACKGROUND OF THE PRESENT CASE: WHAT LED TO

THE CASE BEING BROUGHT BEFORE THE SUPREME

COURT

FACTS OF THE CASE:

Shivrani Dhondiba Kshirsagar, a girl of 6 years of age, was a resident of House no. 14,
Ambedkar nagar, Nanded. The accused was also residing in Ambedkarnagar. He worked in
‘Noor Garage’ as a mechanic and used to repair two-wheelers. On 16 th December, 1989, at
around 2:00pm in the afternoon, he lured the said girl by saying that he would give her a ride
on his Luna. Being a kid, she was cajoled to go with him. Thereafter, he took the girl towards
the Aerodrome. People tried to find her, but were unsuccessful. Later, when she came back to
her house, she was crying and weeping. When asked by her mother, she explained her that
the person who was a mechanic had taken her in the direction of the Aerodrome on the Luna
and after that, he removed her nicker and urinated on his private part. As a result, she was
experiencing pains in her private part. When the father of the girl arrived, Vandana, her
mother told him about the happening.The girl also narrated the incident to her father. After
coming to know about this, the father searched for the said person, but he could not be found.

5
As the night had set in, an FIR could not be lodged. The following day, the girl was taken to
the said ‘Noor Garage’ and the person was identified as the one who had committed the said
act. Thereafter, an FIR was lodged. Dr. Sheela Kadam medically examined the girl. The
following things were explained in the medical report.

1. The hymen was intact.

2. There was no evidence of injury over the vulva.
3. External anal spinchter was abraded anteriorly and laterally about cm x cm. Redness
of spinchter PR was powerful.
4. For vaginal examination was not possible.
5. There was no semen deposit and the hymen was intact. So wet smear for sperm was
taken through rectum. Negative.
There is evidence of intercourse through rectum.

JUDGMENT

While a chargesheet was filed against the accused pursuant to Sections 363 and 376 of the
Indian Penal Code, it was amended to one pursuant to Sections 363, 376 and Sections 511
and 377 thereof .

Not only the girl, but also her mother Vandana Dhondiba Kshirsagar and her father Dhondiba
Kishan Kshirsagar were examined before the learned Sessions Judge. The learned Sessions
Judge found the charges to have been proven against the accused, believing the testimony of
the aforementioned witnesses. Under Sections 363, 376, read with Section 511 and Section
377 IPC, he was convicted. He was sentenced under Sections 363, 376/511 and 377 IPC
respectively to rigorous imprisonment for three years, five years and seven years and to a fine
of Rs. 2,000/- under Section 363 and Rs. 3,000/- under Section 376/511 and 377 IPC
respectively.

By reason of the impugned judgement, the High Court rejected the appeal preferred by the
appellant in the case.

The present case is an appeal against this judgement and order dated 27.01.2005 which was
passed by a learned single judge of Aurangabad bench of the Bombay High Court in Criminal
Appeal no. 23 of of 1991 where the appellant’s appeal against the judgment of his conviction

6
and sentence dated 16.01.1991 was dismissed. The appellant, therefore, is before the
Supreme Court.

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CHAPTER-2

SIZE OF THE BENCH

It is a division bech i.e., a 2 judge bench.

NAME OF THE JUDGES

Satya Brata Sinha and Markandey Katju

JUDGE WHO DELIVERED THE OPINION

S.B. Sinha

ADVOCATES ON BEHALF OF THE APPELLANT

Sanjay Visen, Sanjeev Kumar Choudhary and P.V. Yogeswaran

ADVOCATES ON BEHALF OF THE RESPONDENT

Gautam Godara, Sushil Karanjkar, and Ravindra Keshavrao Adsure

INTERVENOR/AMICUS- N/A

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MATERIAL FACTS

Appellant herein is a citizen of Ambedkarnagar, Nanded. He was a two-wheeler-mechanic.

Also residing at House No. 14, Ambedkarnagar, Nanded, was one Shivrani Dhondiba
Kshirsagar, aged around 6 years at that time. He lured the said child to ride his Luna with
him. He brought her to the aerodrome. After a while, s he returned to her house crying and
weeping. The High Court noticed that, when asked by her mother, the presocutrix said that
the guy who used to fix Luna had taken her to  aerodrome, and he urinated on his private part
after removing her nicker. She also said that she was getting pains in her private part as a
result of the same. After arrival of the father of the prosecutrix, Vandana, the mother of the
prosecutrix recounted the incident to him. The father then tried to look for the person who
had committed the above incidents, but he was not found. The girl was taken to the 'Noor
Garage' on the next day, where the appellant was confirmed as the person who on the
previous day had committed the said act against her. The First Information Report was
subsequently lodged. Dr. Sheela Kadam, medically examined the prosecutrix. The report
explained the following things:

1. The hymen was intact.

2. There was no evidence of injury over the vulva.
3. External anal spinchter was abraded anteriorly and laterally about cm x cm. Redness
of spinchter PR was powerful.
4. For vaginal examination was not possible.
5. There was no semen deposit and the hymen was intact. So wet smear for sperm was
taken through rectum. Negative.
There is evidence of intercourse through rectum.

The learned Sessions Judge found the charges to have been proven against the accused,
believing the testimony of the aforementioned witnesses. . He was sentenced under Sections
363, 376/511 and 377 IPC respectively to rigorous imprisonment for three years, five years
and seven years and to a fine of Rs. 2,000/- under Section 363 and Rs. 3,000/- under Section
376/511 and 377 IPC respectively.

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ISSUES RAISED

1. The first issue that was raised before the court was whether it was imperative to put
the appellant to a test identification parade.
2. The second issue was whether the Juvenile Justice (Care and Protection of Children)
Act, 2000 was applicable in this case.

Whether question of law or fact or both?

The issue whether the appellant should be put to the test identification parade is a
question of fact as the appellant was already known to the prosecutrix and her family.
The second issue whether the appellant is to be considered a juvenile is a question of
law as it is to decide the ambit of the term Juvenile under the Juvenile Justice act.

CONTENTIONS ADVANCED:

On behalf of the appellant:

The learned counsel acting on behalf of the appellant submitted that since the
prosecutrix had not identified him, it was imperative to put the appellant to a test
identification parade.
The appellant also contended that although his age on the date of occurrence was
more than sixteen years of age but less than eighteen years of age, the necessary
provisions of the Juvenile Justice (Care and Protection of Children) Act, 2000 should
be applied and complied with.

On behalf of the respondent:

The prosecutrix explained that she was lured by the appellant to go on his Luna with
him and after taking her to the Aerodrome, he removed her nicker and urinated on his
private part.

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 RELEVANT SECTIONS/ACTS/ORDERS:
(As mentioned in the case)

1. Juvenile Justice (Care and Protection of Children) Act, 2000:

The primary legislative mechanism for juvenile justice in India is the Juvenile
Justice (Care and Protection of Children) Act, 2000. The Act sets out a
concrete approach to the prevention and treatment of juvenile delinquency and
provides a mechanism for the safety, treatment and rehabilitation of children
within the mechanism of the juvenile justice system. In accordance with the
1989 UN Convention on the Rights of the Child 1 ( UNCRC), this legislation
repealed the earlier 1986 Juvenile Justice Act after India signed and ratified
the 1992 UNCRC. The lower house, On 7 May 2015, passed the bill and the
upper house, On 22 December 2015. The bill was approved on 31 December
2015 with the approval of President Pranab Mukherjee.
Section 20 of the Juvenile Justice Act, 2000 has been mentioned in the case,
which states:
Special provision in respect of pending cases.- Notwithstanding anything contained in this
Act, all proceedings in respect of a juvenile pending in any court in any area on the date on
which this Act comes into force in that area, shall be continued n that court as if this Act had
not been passed and if the court finds that the juvenile has committed an offence, it shall
record such finding and instead of passing any sentence in respect of the juvenile, forward the
juvenile to the Board which shall pass orders in respect of that juvenile in accordance with
the provisions of this Act as if it had been satisfied on inquiry under this Act that a juvenile
has committed the offence.2

1
The United Nations Convention on the Rights of the Child is a treaty on human rights that sets out children's
legal, political , economic, educational , health and cultural rights.
2
Juvenile Justice (Care And Protection Of Children) Act, 2000

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 2. Section 363 of the Indian Penal Code:

Punishment for kidnapping.--Whoever kidnaps any person from 1*[India] or from lawful
guardianship, shall be punished with imprisonment of either description for a term which may
extend to seven years, and shall also be liable to fine.3
Section 363 provides for the punishment for the kidnapping crime specified in s
361(Kidnapping from lawful guardianship). There may be a convict sent to
Prison for a term of up to seven years to endure simple or rigorous imprisonment and
to be asked to pay a fine,
The Supreme Court refused to convict the father in Chandrakala v Vipin Menon, who was
accused of kidnapping his minor daughter who lived with her maternal grandfather because
of the strained relationship between her parents, on the ground that the accused was the
child's natural guardian.

3. Section 376 of the Indian Penal Code:

Section 375 of the IPC defined rape. The essential ingredients of the section
are:
(i)Sexual intercourse must occur, as understood in conditions of the provisions
of s 375(a) to (d), a man's intercourse with a woman; (ii) such intercourse must
be under  any of the seven circumstances: (a) against her will; (b) without her
consent; (c) gaining her consent;
(d) under the misconception that the man is her husband; (e) consent given
under the misconception that the man is her husband; (e) consent provided by
unsoundness of mind, intoxication or some stupefying or under the influence
of stupefying or unwholesome substance; (f) with a woman under the age of
eighteen, with or without her consent; or (g) with a woman under the age of
eighteen; a woman who is not in a position to express her consent.

The punishment for rape is given under Section 376. It contains two sub-
sections. The first sub-section is in general respect of rape. The second sub-
section concerns the cases of other types of rape, which are, subject to extreme
punishment in contrast to the former.

3
The Indian Penal Code, 1860 Act no. 45 OF 1860 1* [6th October, 1860.)

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 Punishment for rape.--(1) Whoever, except in the cases provided for by sub-
section (2), commits rape shall be punished with imprisonment of either
description for a term which shall not be less than seven years but which may
be for life or for a term which may extend to ten years and shall also be liable
to fine unless the woman raped is his own wife and is not under twelve years
of age, in which case, he shall be punished with imprisonment of either
description for a term which may extend to two years or with fine or with
both:
Provided that the court may, for adequate and special reasons to be mentioned
in the judgment, impose a sentence of imprisonment for a term of less than
seven years.4
A comparative reading of the two subsections of s 376 of the IPC indicates
three characteristics of the revised s
(a) 376(2). Second, it not only expands the definition of 'rape' by introducing a
few additional types of non-consensual rape to it,
But sexual intercourse also provides the perpetrator with strict punishment.
Secondly, it extracts the prevailing judicial power to grant a punishment lower
than the minimum punishment (i.e. rigorous ten years' imprisonment) for
'adequate and special purposes'. Thirdly, it's like the pre-amended s 376(2),
allows for life imprisonment, but it makes clear reference to life
imprisonment- for the rest of his natural life.

4. Section 377 of the Indian Penal Code:

Unnatural offences.--Whoever voluntarily has carnal intercourse against the

order of nature with any man, woman or animal, shall be punished with
1*[imprisonment for life], or with imprisonment of either description for a
term which may extend to ten years, and shall also be liable to fine.
Explanation.-Penetration is sufficient to constitute the carnal intercourse
necessary to the offence described in this section.5

4
Section 376, The Indian Penal Code, 1860 Act no. 45 OF 1860 1* [6th October, 1860.)
5
Section 377, The Indian Penal Code, 1860 Act no. 45 OF 1860 1* [6th October, 1860.)

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Unnatural carnal intercourse is punishable by Section 377 and refers to the
crimes of sodomy and bestiality under English law. Consent is wholly
meaningless under this clause. As an abettor, the party consenting will be
similarly liable. Penetration, as in the case of rape, however limited it is, is
required to constitute the 'carnal intercourse' by virtue of the explanation
appended to it. It is necessary to attract s 377 to voluntary 'carnal intercourse
against the order of nature' with a man, woman or animal evinced by
'penetration'.
The main words,' carnal intercourse' and 'penetration,' are not specified in the
IPC.
The High Court of Kerala was invited to interpret 'carnal intercourse' and
'penetration' in 1969. It has been renamed to determine whether an act of
inserting a male organ between the thighs held together and close leads to a
'carnal intercourse against the order of nature' and thus the doer falls under the
'unnatural offense' clutches. The High Court held that an act of inserting the
male organ between the thighs of another amounts to an unnatural offence
contrary to s 377, giving a very limited concept of 'intercourse'.
A plethora of its earlier judicial pronouncements were referred to and relied on
by the Supreme Court to rule that s 377 is intra-vires. The Supreme Court
claimed that in its concern to preserve the so-called rights of LGBT persons
and to declare that section 377 of the Indian Penal Code violates the right to
privacy, autonomy and integrity, the High Court has relied extensively on the
judgments of other jurisdictions, expressing its displeasure over the Delhi
High Court’s reliance on international judicial opinions. Although these
decisions shed considerable light on different aspects of this right and are
insightful in relation to the situation of sexual minorities, we conclude that
they should not be used blindfolded to determine the constitutionality. The
apex court, recalling the 'presumption of constitutionality' in favour of law,
reminded higher courts that they were reluctant to declare a law null or ultra
vires on account of unconstitutionality and then advised to return to the
'principle of reading down or reading into' the provision to make it functional,
workable and ensure that the purpose of the Act was achieved. One of the last
remedies adopted by the courts is to find the law unconstitutional passed by
the Indian legislature.'

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 5. Section 511 of the Indian Penal Code:

Punishment for attempting to commit offences punishable with imprisonment

for life or other imprisonment.--Whoever attempts to commit an offence
punishable by this Code with 1*[imprisonment for life] or imprisonment, or to
cause such an offence to be committed, and in such attempt does any act
towards the commission of the offence, shall, where no express provision is
made by this Code for the punishment of such attempt, be punished with
2*[imprisonment of any description provided for the offence, for a term which
may extend to one-half of the imprisonment for life or, as the case may be,
one-half of the longest term of imprisonment provided for that offence], or
with such fine as is provided for the offence, or with both.6

BOOKS/LITERATURE/ARTICLES:
1. PSA Pillai: Criminal Law,12th Edition:
The Criminal Law of PSA Pillai is one of the most archetypal texts of the
Indian Penal Code, 1860, ever since its first edition was written in 1956. This
work adopts a radically different approach to the study of the law of crime,
concentrating on both new problems and legislative trends, with a section wise
material flow. This thesis, a leading treatise on the topic for more than five
decades, is a thematic presentation, in a lucid, detailed and systematic way, of
the complex and multi-dimensional subject of criminal law. The book also
discusses all the applicable provisions of the Code of Criminal Procedure,
1973, and the Indian Evidence Act, 1872, specifically dealing with the
substantive offences contained in the Indian Penal Code.
Main Functionalities:

A critical commentary addressing both current issues and legislative changes.

6
Section 511, The Indian Penal Code, 1860 Act no. 45 OF 1860 1* [6th October, 1860.)

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It reflects on the changes made since the last publication in the law relating to
criminal law.

It traces the near interrelationship between the laws of the Indian Penal Code,
the Criminal Procedure Code and the Indian Evidence Act.

Contains and addresses the Criminal Law Amendment in depth in 2013 and
2018.

It requires a critical evaluation of the Indian Courts' decisions that have

contributed to the shift and improvement of the legal situation.

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CHAPTER-3

CASES REFERRED:

There were two cases which were referred in this particular case.
The first case was only mentioned while the other case was discussed.

1. Amitsingh Bhikamsing Thakur v. State of Maharashtra7:

In this case, it was noted and said by the court that Identification of the accused by
a parade of test identification often has no legal meaning. Identification tests are
not substantive evidence. They are mainly intended to assist the investigative
agency with the confidence that their progress is on the right lines with the inquiry
into the offence. Only as a corroborative statement in court can the identification
be used. Only when the accused is not previously identified to the witnesses will
the need to conduct an identification parade occur. The whole premise of a parade
of test identification is that witnesses who claim to have seen the suspects at the
time of incident are to identify them without any help or any other source from
among other people. The test is performed in order to verify their veracity. In
other words, during the investigation stage, the main purpose of conducting an
identification parade is to test the memory of the witnesses on the basis of the first
experience and also allow the prosecutor to determine if any or any of them may
be cited as eyewitnesses to the crime.
The Court, to answer the issue of the need of a test identification parade used the
above mentioned case and held that since the prosecutrix and her family members
already knew the appellant, there was no need of this test. And otherwise, the
substantive evidence is the evidence of court identification.

7
Amitsingh Bhikamsing Thakur v. State of Maharashtra MANU/SC/7004/2007

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 2. Pratap Singh v. State of Jharkhand and Anr.8

In this case, the application of the provisions of Section 20 of the Juvenile Justice
Act(Care and Protection of Children), 2000 was considered by this court’s
Constitution Bench wherein it was held that:
Section 20 of the Act as quoted above deals with the special provision in respect of pending
cases and begins with non-obstante clause. The sentence "notwithstanding anything contained
in this Act, all proceedings in respect of a juvenile pending in any court in any area on date of
which this Act came into force" has great significance. The proceedings in respect of a
juvenile pending in any court referred to in Section 20 of the Act are relatable to proceedings
initiated before the 2000 Act came into force and which are pending when the 2000 Act came
into force. The term "any court" would include even ordinary criminal courts. If the person
was a "juvenile" under the 1986 Act the proceedings would not be pending in criminal courts.
They would be pending in criminal courts only if the boy had crossed 16 years or girl had
crossed 18 years. This shows that Section 20 refers to cases where a person had ceased to be
a juvenile under the 1986 Act but had not yet crossed the age of 18 years then the pending
case shall continue in that Court as if the 2000 Act has not been passed and if the Court finds
that the juvenile has committed an offence, it shall record such finding and instead of passing
any sentence in respect of the juvenile, shall forward the juvenile to the Board which shall
pass orders in respect of that juvenile.9

This Rule also indicates that the intention of the Legislature was that the
provisions of the 2000 Act were to apply to pending cases provided, on 1.4.2001
i.e. the date on which the 2000 Act came into force, the person was a "juvenile"
within the meaning of the term as defined in the 2000 Act i.e. he/she had not
crossed 18 years of age.10

(b) The 2000 Act would be applicable in a pending proceeding in any

court/authority initiated under the 1986 Act and is pending when the 2000 Act

8
Pratap Singh v. State of Jharkhand and Anr. MANU/SC/0075/2005
9
Pratap Singh v. State of Jharkhand and Anr. MANU/SC/0075/2005
Jameel vs. State of Maharashtra (16.01.2007 - SC) : MANU/SC/7020/2007
10
Pratap Singh v. State of Jharkhand and Anr. MANU/SC/0075/2005

18
 came into force and the person had not completed 18 years of age as on
1.4.2001.11
Keeping this in mind the court held that by 01.04.2001, the appellant was over
eighteen years of age. Therefore, in the present case, 2000 Act cannot have any
application whatsoever.

CONCRETE JUDGMENT
11
Pratap Singh v. State of Jharkhand and Anr. MANU/SC/0075/2005

19
 (JUDGMENT IN PERSONAM)
The fact that both the appellant and the prosecutor are from the same town does
not constitute a conflict. Also, it is not denied that the appellant was a two-wheeler
mechanic. He was in the 'Noor Garage' working here. Approximately at 2.00 p.m.
On 16.12.1989, the appellant stated to the prosecutor that he would take her for a
ride on his Luna. She was tempted to go with him as well. Nor is the medical
report in question. The recognition of the accused by the prosecutor on the next
day is also shown.

In view of the depositions of the prosecutor and her family, it can not be held that
the learned Sessions Judge, as well as the High Court, committed any mistake in
making the conclusion as noted above.

The High Court has the opinion:

It should not be assumed that sexual intercourse through the rectum had not taken
place merely because there was no proof of stains over the perineum or clothes
and no semen was found. Dr. Sheela Kadam's suggestion on this behalf was
categorically rejected. So, in truth, the medical evidence supports the prosecutor's
version. We can not leap to the conclusion that there was no effort on the part of
the accused to commit rape on prosecutrix merely because prosecutrix claimed
that the accused placed his penis on her private part and urinated there and did not
explicitly say that he had inserted his penis in her vagina on her private part. The
fact that the prosecutor is hardly six years of age must be taken into account, and
whatever act the accused committed, she may have assumed that the accused
urinated there, but in truth, the evidence reveals that he must have attempted to
rape the prosecutrix.12
In our view, the deposition of the prosecutor clearly reveals that she was a
completely innocent child. As far as the argument by the learned counsel
concerning the non-holding of the appellant’s test identification parade is
concerned, we are of the opinion that it would have been pointless to conduct a
test identification parade, taking into account the fact that the appellant was

12
Jameel vs. State of Maharashtra (16.01.2007 - SC) : MANU/SC/7020/2007

20
 known to the prosecutor and her family members and that she had recognised him
before the F.I.R. was lodged. And otherwise, the substantive evidence is the
evidence of court identification.13So the court held that the prosecution has proved
their case.

As far as the argument made by the learned counsel concerning the applicability of the 2000
Act is concerned, it is not contested that the appellant had attained the age of sixteen at the
date of the occurrence. The offence having been committed on 16.12.1989, the 2000 Act has
no application. Juvenile "was identified as" a boy who had not reached the age of sixteen or a
girl who had reached the age of eighteen "in terms of the Juvenile Justice Act, 1986.14

In any court / authority instituted under the 1986 Act, the 2000 Act will be applicable in a
pending proceeding which is pending as the 2000 Act came into force and the individual was
not 18 years of age as of 1.4.2001.

By 01.04.2001, the appellant was over eighteen years of age. Accordingly, in the present
case, 2000 cannot have any request whatsoever. There is no substance in this appeal, which is
accordingly rejected, for the reasons alluded to above.15

RATIO DECIDENDI

(JUDGMENT IN REM)
The ratio decidendi in this case was held to be that:
Rape - Test Identification parade - Having regard to the fact that the appellant was known to
the prosecutrix and her family members and she having identified him before lodging of the
F.I.R., it would have been futile to hold a test identification parade.
Applicability - Offence having been committed on 16.12.1989, the 2000 Act has no
application.16

13
Amitsingh Bhikamsing Thakur v. State of Maharashtra MANU/SC/7004/2007
14
Pratap Singh v. State of Jharkhand and Anr. MANU/SC/0075/2005
15
Jameel vs. State of Maharashtra (16.01.2007 - SC) : MANU/SC/7020/2007
16
Jameel vs. State of Maharashtra (16.01.2007 - SC) : MANU/SC/7020/2007

21
CONCLUSION

The judgment given by the judges are in my opinion, correct and very well
written. It has helped understand the Juvenile Justice Act in a better manner. By
clearing out the meaning of juvenile, this case has paved a way for the future
judgments. There have been cases where the offenders have tried to take the help
of this act to evade the clutches of law. This case will help in preventing that.

22