XXX v. State of Haryana, 2026

The appellant was convicted under Sections 302, 506 read with Section 34 IPC in an FIR registered in 2022.

The trial court treated the accused as a child in conflict with law, but tried him as an adult under Section 19 of the Juvenile Justice Act, 2015.

The trial court imposed:

• 10 years rigorous imprisonment for murder under Section 302 IPC

• 6 months imprisonment under Section 506 IPC

The appellant challenged the sentencing before the Punjab and Haryana High Court.

It was argued that the sentence was legally unsustainable as Section 302 IPC does not permit a fixed-term sentence.

The Punjab and Haryana High Court held that the 10-year sentence under Section 302 IPC is ex facie illegal.

The Court observed that Section 302 IPC prescribes only two punishments:

• Death penalty, or

• Imprisonment for life

The Court clarified that no statutory basis exists for a fixed-term sentence of 10 years under Section 302 IPC.

The Bench held that the trial court had committed a fundamental sentencing error.

The Court examined the interplay between Sections 19 and 21 of the Juvenile Justice Act, 2015.

It clarified that even when a juvenile is tried as an adult, the sentence must comply with reformative principles of juvenile justice.

The Court held that under Section 21 of the Juvenile Justice Act, a child cannot be sentenced to:

• Death penalty, or

• Life imprisonment without possibility of release

The Court clarified that if convicted for murder, the only permissible sentence is life imprisonment with the possibility of release, not incarceration till natural life.

The Bench emphasised that the legislature intended to ensure reform and rehabilitation of children in conflict with law.

The Court found that the trial court had misinterpreted statutory provisions while imposing sentence.

However, instead of directly modifying the sentence, the High Court chose to remand the matter back to the trial court.

The Court reasoned that the accused must be given an opportunity to be heard on sentencing considerations.

It observed that imposing life imprisonment directly at the appellate stage could prejudice the rights of the accused under the Juvenile Justice framework.

Accordingly, the Court:

• Set aside the 10-year sentence under Section 302 IPC

• Remanded the matter to the trial court for fresh sentencing in accordance with law

The judgment reinforces the strict sentencing framework under Section 302 IPC, which allows only death or life imprisonment.

It clarifies that courts cannot invent intermediate punishments not prescribed by statute.

The decision strengthens the reformative approach of juvenile justice law in India.

The Court emphasised the protective scope of the Juvenile Justice Act, 2015, even when juveniles are tried as adults.

The ruling ensures that children are not subjected to irreversible or excessively harsh punishments.

The decision highlights the importance of procedural fairness in sentencing, including the right to be heard.

The Court maintained a balance between correcting illegality and protecting the accused’s due process rights.

The remand approach reflects judicial caution in not directly imposing enhanced punishment without hearing the convict.

The judgment serves as a reminder that sentencing must strictly adhere to statutory limits.

It strengthens jurisprudence on the intersection of criminal law and juvenile justice principles.