The court held that despite the general rule of granting bail to juveniles, the recovery of a commercial quantity of narcotics from a vehicle the juvenile was occupying justifies the rejection of bail based on the gravity and nature of the offence.

1. The present Criminal Revision has been preferred under Section 102 of the Juvenile Justice (Care and Protection of Children) Act, 2015 by the applicant (juvenile in conflict with law) through his guardian, challenging the legality and propriety of the order dated 12.02.2026 passed by the learned Children Court/Additional Sessions Judge, FTC, Mahasamund, District–Mahasamund (C.G.) in Criminal Appeal No. H11/2026, whereby the appeal preferred by the present applicant against the order dated 02.02.2026 passed by the Juvenile Justice Board, Mahasamund in Crime No. 67/2025, rejecting the application for grant of bail to the juvenile, has been dismissed. Hence, the present revision for grant of bail.

2. The prosecution case, in brief, is that on 07.08.2025, Assistant Sub-Inspector Nilambar Singh Netam of Police Station Singhoda had proceeded for rural patrolling along with his accompanying staff. During the course of patrolling, on the basis of information received from an informer, a grey coloured car bearing registration No. CG-10/BJ-5828 was intercepted on National Highway No. 53 near village Rehatikhol. Upon conducting a search of the said vehicle, apart from the juvenile in conflict with law, two other persons namely Gagan Singh Bhatiya and Durgesh Kumar Sahu were found present in the car. Upon searching the car, a total of 45.0 kilograms of contraband substance ganja, having a total value of Rs. 6,75,000/-, was found illegally kept therein. When questioned regarding the said contraband substance, they stated that the said ganja was being transported from Odisha to Raipur. Thereafter, the police recorded a Dehati Nalishi at the spot. The seized contraband substance and the vehicle were seized from the joint possession of the accused persons. After returning to the police station, Crime No. 67/2025 was registered against the accused persons under Section 20(b) of the Narcotic Drugs and Psychotropic Substances Act. During the course of investigation, it was revealed that the juvenile/applicant, aged about 17 years, was a minor. Consequently, his case was separated from that of the other accused persons and he was arrested and produced before the Juvenile Justice Board, Mahasamund, from where he was sent to the Observation Home, Mahasamund.

3. After completion of investigation, the charge-sheet has been filed on 11.12.2025, wherein it has been alleged that the present juvenile was working as a household servant of co-accused Gagan Singh Bhatiya.

4. An application under Section 12 of the Juvenile Justice (Care and Protection of Children) Act, 2015 was filed on behalf of the juvenile seeking grant of bail, however, the said application was dismissed by the Juvenile Justice Board, Mahasamund, District–Mahasamund (C.G.) vide order dated 02.02.2026.

5. Being aggrieved by the said order, the applicant preferred Criminal Appeal No. H11/2026 under Section 101 of the Juvenile Justice (Care and Protection of Children) Act, 2015 before the learned Children Court/Additional Sessions Judge, FTC, Mahasamund. The said appeal has also been dismissed vide impugned order dated 12.02.2026. Hence, the present criminal revision.

6. Learned counsel for the applicant submits that the learned Courts below have failed to appreciate the true scope and mandate of Section 12 of the Juvenile Justice (Care and Protection of Children) Act, 2015, which provides that a child in conflict with law shall ordinarily be released on bail unless the case falls within t