IN THE HIGH COURT OF MADHYA PRADESH AT JABALPUR BEFORE HON’BLE SHRI JUSTICE RAMKUMAR CHOUBEY ON THE 13^th OF OCTOBER, 2025 CRIMINAL REVISION NO.3547/2025 CHILD UNDER CONFLICT WITH LAW VS.

THE STATE OF MADHYA PRADESH ------------------------------------------------------------------------------------------

Appearance:

Petitioner by Shri Kuldeep Singh, Advocate.

Respondent/State by Shri Kamal Nath Naiyak, Panel Lawyer.

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ORDER

Heard finally.

2. This revision petition has been filed under Section 102 of the Juvenile Justice (Care and Protection of Children) Act, 2015 (for brevity “Act, 2015”) being aggrieved by the order dated 09.07.2025 passed by learned Fifth Additional Session Judge, Waidhan, District Singrauli in Criminal Appeal No.54/2025 affirming the order dated 20.02.2025 passed by learned Principal Magistrate, Juvenile Justice Board, Waidhan District Singrauli, dismissing the bail application.

3. As per the prosecution case, on the basis of information given by the complainant Brajbihari, an FIR vide Crime No.16/2025 for the offences punishable under Sections 103(1), 331, 238, 3(5) of BNS, 2023 has been registered against the accused persons including the petitioner for committing the murder of four persons and hiding their dead bodies in a septic tank. The petitioner was produced before the concerned court and the learned Magistrate vide order dated 20.02.2025 rejected the application filed under Section 12 of the Act, 2015. The petitioner preferred an appeal against the said order dated 20.02.2025 and the learned appellate Court vide impugned order dated 09.07.2025 considering the moral, physical and psychological affects and apprehension of association with known criminals, dismissed the appeal.

Hence this revision.

4. Learned counsel for the petitioner has submitted that the findings of the learned appellate Court are based on assumptions and presumptions rather than on cogent legal reasoning, which are contrary to the statutory protection under Section 12 of the Act, 2015. It is further submitted that social investigation report suggests nothing but reflects social economic environment where the petitioner was born.

5. On the other hand, learned counsel for the respondent/State has opposed the prayer of the petitioner on the ground that there are clear allegations of commission of alleged offence along with co- accused. Therefore, learned Appellate Court has not committed any illegality in passing the impugned order and in keeping the juvenile in Child Reformation Center. Under these circumstances, it is prayed that this revision may be dismissed.

6. Heard the learned counsel for the parties and perused the record.

7. Indeed, there is an allegation for committing offence by the petitioner, who is aged about 17 years and is an accused of murder of four persons and hiding their corpses in a septic tank. It is also gathered that the petitioner is immured in observation home since 20.02.2025.

8. There is an amendment (23 of 2021) made under the provision of Act, 2015, which is made in Section 18 of Act, 2015 w.e.f. 01.09.2022. Considering this aspect also, it may not be proper to release the child in conflict with law on bail.

9. Further, although, the Social Investigation Report submitted to this Court contains certain observations in favour of the petitioner, but same does not suggest that the release of the petitioner will save his interest. Obviously, the offence is heinous in nature as it is a case of quadruple murder and present petitioner though adolescent, aged about 17 years, but looking to the observations made by the learned Principal Magistrate as well as learned Additional Sessions Judge and looking to the facts and circumstances of the event, there appears reasonable grounds for believing that release is likely to bring the petitioner into association of known criminal or expose