X v. State of Rajasthan & Others, 2025

The case arose from a POCSO trial where the accused-respondent claimed juvenility.

The trial court accepted the accused’s application, relying on his matriculation certificate and Aadhaar card.

Petitioner challenged this order arguing:

• The juvenility claim was made thrice, withdrawn twice, and filed again late in trial hence barred by res judicata.

• The documents used (matric certificate & Aadhaar) were not reliable, especially since basis of age entry was unclear.

Respondent argued the prosecution's document was forged, citing father's inconsistent signature.

The High Court held that enquiry into juvenility is not equivalent to a full criminal trial.

If two views are possible, courts should lean in favour of juvenility, especially in borderline cases.

Documents under Section 94 JJ Act (matriculation certificate, Aadhaar) must be accepted unless proven to be fabricated.

The only when documents are shown to be manipulated, should the court opt for medical tests.

The rejected petitioner’s res judicata and delay arguments, clarifying that juvenility claims can be raised even at the final stage of trial.

It was concluded that respondent’s documents (matric certificate, Aadhaar) were reliable, and prosecution failed to disprove them.

This ruling reinforces that juvenility claims are special and remedial, and courts must favor rehabilitation over punishment.

It clarified the limited scope of inquiry under Section 94, which prioritizes official documents and discourages unnecessary medical testing.

The Court adopted a child-friendly interpretation, aligned with the protective spirit of the JJ Act.

The judgment also protects procedural flexibility, ensuring juvenility claims are not struck down on technical delays or formalistic bars like res judicata.

Reflects reliance on Supreme Court precedent and reaffirms that standard of proof is relaxed unless fabrication is shown.