The Madhya Pradesh High Court at Gwalior has granted bail to a child in conflict with law after finding that there was no material on record to show that the juvenile's release would attract any of the exceptions contained in the Juvenile Justice (Care and Protection of Children) Act, 2015.
Justice Anand Singh Bahrawat allowed the criminal revision petition and set aside the orders of both the Juvenile Justice Board and the appellate court, which had earlier refused bail.
Background of the Case
The revision petition was filed under Section 102 of the Juvenile Justice Act challenging the orders dated April 2, 2026, and April 9, 2026, by which the juvenile's application for bail under Section 12 of the Act had been rejected. The juvenile had been in custody since April 1, 2026, in connection with a criminal case registered at Cantt Police Station, Guna district.
Counsel for the juvenile argued that the lower courts had primarily relied on the seriousness of the allegations while denying bail. It was contended that there was no evidence suggesting that the child would come into contact with known criminals, face moral or psychological danger, or defeat the ends of justice if released.
The State opposed the plea, submitting that the nature of the allegations and circumstances of the incident justified the rejection of bail.
After examining the record, the High Court referred to Section 12 of the Juvenile Justice Act, which provides that a child alleged to be in conflict with law should ordinarily be released on bail unless specific statutory exceptions are established.
The Court also considered the Probation Officer's report, which indicated that the possibility of improvement in the child's conduct under proper family supervision could not be ruled out.
Justice Bahrawat observed that there was no specific material showing that the juvenile's release would bring her into association with known criminals, expose her to moral, physical, or psychological danger, or otherwise defeat the ends of justice.
“The applicant is a juvenile and except the gravity of the alleged offence, there is no specific material available on record,” the Court observed while considering the statutory requirements for denial of bail.
Holding that no exceptional circumstance existed to deny bail, the High Court allowed the revision petition and quashed the orders passed by the Juvenile Justice Board and the appellate court.
The Court directed that the juvenile be released into the custody of her father upon furnishing a personal bond of ₹50,000 along with one solvent surety. The release was made subject to several conditions, including cooperation with the proceedings, regular reporting to the Probation Officer, supervision by the father, and appearance before the Juvenile Justice Board whenever required.
The criminal revision was accordingly allowed.
Case Details
Case Title: Child in Conflict with Law v. State of Madhya Pradesh
Case Number: Criminal Revision No. 1704 of 2026
Judge: Justice Anand Singh Bahrawat
Decision Date: May 25, 2026
