Supreme Court Reaffirms Primacy of Documentary Evidence Over Medical Tests in Juvenile Age Determination

In a significant ruling that reinforces the evidentiary hierarchy under the Juvenile Justice (Care and Protection of Children) Act, 2015 (JJ Act), the Supreme Court has held that statutory documents such as school or birth certificates must take precedence over medical assessments when determining the age of an individual accused under the Act. This decision, delivered in the case of Rajni vs. State of Uttar Pradesh & Anr, underscores the primacy of documentary evidence in age determination proceedings.

Legal Framework and Hierarchy of Evidence

Section 94(2) of the JJ Act delineates a clear order of preference for age determination:

1. Date of birth certificate from the school or matriculation, or equivalent certificate from the concerned examination board.

2. In the absence of the above, the birth certificate issued by a corporation or municipal authority, or a panchayat.

3. Only in the absence of such documents, age may be determined by an ossification test or any other medical age determination test.

4. This statutory framework emphasizes that documentary evidence should be the primary basis for age determination, with medical assessments serving as a last resort.

Judicial Precedents Reinforcing the Statutory Mandate

The Supreme Court's ruling aligns with its earlier decisions, notably in Rishipal Singh Solanki v. State of Uttar Pradesh, where it was held that the procedure for age determination must adhere to the hierarchy outlined in Section 94(2) of the JJ Act. Similarly, in Vinod Katara v. State of U.P., the Court reiterated that the date of birth certificate from the school stands at the highest pedestal, and ossification tests are to be considered only in the absence of reliable documentary evidence.

The Supreme Court's affirmation of the primacy of documentary evidence in age determination under the JJ Act serves to uphold the rights of juveniles and ensure consistency in legal proceedings. Legal practitioners must diligently procure and present the requisite documents to substantiate claims of juvenility, thereby facilitating the fair and just application of the law.

Implications for Legal Practitioners and Judicial Bodies

This ruling has significant implications for legal practitioners and judicial bodies handling cases under the JJ Act:

●        Prioritization of Documentary Evidence: Courts and Juvenile Justice Boards must prioritize statutory documents over medical assessments when determining age.

●        Avoidance of Unnecessary Medical Tests: In the presence of credible documentary evidence, courts should refrain from ordering medical tests, which may be invasive and less reliable.

●        Ensuring Fair Treatment of Juveniles: Accurate age determination is crucial to ensure that juveniles receive the protections and rehabilitative measures intended under the JJ Act.

Conclusion

The Supreme Court’s ruling reinforces the statutory mandate under the Juvenile Justice Act, ensuring that documentary evidence like school or birth certificates prevails in age determination. This not only upholds legal certainty but also safeguards the rights of juveniles. Legal professionals must prioritize such documents to ensure due process and prevent undue reliance on less reliable medical assessments.