Citation : 2026 Latest Caselaw 3529 MP
Judgement Date : 15 April, 2026
NEUTRAL CITATION NO. 2026:MPHC-IND:9942
1 CRR-6206-2025
IN THE HIGH COURT OF MADHYA PRADESH
AT INDORE
BEFORE
HON'BLE SHRI JUSTICE GAJENDRA SINGH
ON THE 15th OF APRIL, 2026
CRIMINAL REVISION No. 6206 of 2025
CHILD IN CONFLICT WITH LAW THROUGH NATURAL GUARDIAN
Versus
THE STATE OF MADHYA PRADESH
Appearance:
Shri Govind Pal Singh Songara - Advocate for the appellant.
Shri Prashant Jain - GA for the State.
Shri Vipul Pal- Advocate for the complainant.
ORDER
This criminal revision is preferred under section 102 of the Juvenile Justice Act, 2015 challenging the order dated 06.11.2025 in Criminal Appeal No.286/2025 by the 2nd Additional Session Judge, Children's Court, Indore arising out of order dated 12.09.2025 by Principal Magistrate, Juvenile Justice Board, Indore whereby the application of the child in conflict with law in relation with crime No.309/2025 registered at police station- Khudel,
District Indore (M.P.) has been rejected and the child in conflict law has been denied to be handed over on supurdgi.
2 . Facts in brief are that child in conflict with law was produced before the Juvenile Justice Board, Indore in connection with crime No.309/2025 registered at police station- Khudel, District- Indore (M.P.) for the offence punishable under section 5(L)/6 of the POCSO Act, 2012.
NEUTRAL CITATION NO. 2026:MPHC-IND:9942
2 CRR-6206-2025 3 . The Juvenile Justice Board, Indore rejected the application of the child in conflict with law recording the finding that present the atmosphere of the house of the child in conflict with law is not in favour of the child in conflict with law to grant him bail and the parents of the child in conflict with law are semi illiterate.
4. Second Additional Session Judge, District Indore have also rejected the application recording the finding that parents of the child in conflict with law are semi-illiterate and possibility that child in conflict with law will come in the company of the known and unknown criminals cannot be ruled out.
5. Challenging the order, this revision has been preferred on the
ground that the impugned orders are in violation of the provision of section 12 of the Juvenile Justice Act, 2015 and both the Courts have not considered the social investigation report.
Heard.
6 . Learned counsel for the State and as well as complainant has opposed the criminal revision and prayed for its dismissal.
7 . Social Investigation Report dated 13.03.2026 does not mentions any previous exposure of the child in conflict with law. Para-8 of the Social Investigation Report is being reproduced as under:-
''बालक का प रवार आ दवासी समाज से है एवं सामा जक प रवेश म िनवासरत ् है । प रवार के सभी सद य िनर र ह प रवार मजदरू पर आि त है । बालक दनांक 25.06.2025 म स े ण गृह क अिभर ा म है । य प बालक िनर र है परं तु बालक ने सं था म रहकर अपना नाम हं द एवं अं ेजी भाषा म िलखना सीख िलया है । बालक ने सं था क
NEUTRAL CITATION NO. 2026:MPHC-IND:9942
3 CRR-6206-2025 अिभर ा म म डला ऑ स, इले क सीर ज, राखी, जूट के बैग एवं िम ट क मूित बनाने म िश ण ा कया है । बालक का आचरण एवं यवहार सं था म अ छा है । बालक के भ व य को गत रखते हुए उसे प रवार के मा यम से पुनवास कया जाना उिचत तीत होगा।''
8 . In view of the above, this revision is allowed and the impugned order is hereby set aside and it is directed that the juvenile shall be released on bail and handed over to the custody of his guardian/father on furnishing a personal bond of Rs.50,000/- (Rupees Fifty Thousand) with one solvent surety in the like amount to the satisfaction of the Juvenile Justice Board, Indore subject to the condition that the guardian/father of the juvenile shall keep watch over him during the period of his release and keep him present on each and every date of appearance before the Juvenile Justice Board and shall not allow the minor to come into association with any known/unknown criminals and further ensure that his release shall not defeat the ends of justice in any manner.
9 . It is further directed that Probation Officer shall periodically keep vigilance over the child conflicted with law and observe his activities and in the event of any adversity noticed by him, he shall inform the Juvenile Justice Board and the Board, after proper enquiry, if found the activities of the conflicted child adverse to law, may send the juvenile to Child Reformation Center and in such condition, this order regarding granting of child custody shall stand automatically cancelled without further reference to this Court.
10. Resultantly, this revision petition stands allowed and disposed of
NEUTRAL CITATION NO. 2026:MPHC-IND:9942
4 CRR-6206-2025 in the manner indicated herein-above, thereby setting aside the impugned orders.
Certified copy as per Rules.
(GAJENDRA SINGH) JUDGE
ajit
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