Patna High Court Grants Bail to Juvenile in Conflict with Law, Emphasizes Child’s Best Interest

Court Overrules Lower Courts, Highlights Reformatory Approach Under Juvenile Justice Act

In a significant ruling, the Patna High Court has overturned previous orders by the lower courts to grant bail to a minor, Banti Kumar, also known as Aryan Raj or Hunter Yadav, citing the principles of the Juvenile Justice (Care and Protection of Children) Act, 2015. The decision, delivered by Justice Arun Kumar Jha on November 18, 2025, underscores the importance of the child's best interest and reformation, as opposed to the gravity of the alleged offenses.

The case emerged from an incident where Banti Kumar was apprehended with a loaded country-made firearm and a motorcycle with no number plate. Despite being declared a child in conflict with law, his initial bail applications were rejected by both the Juvenile Justice Board and the District & Additional Sessions Judge-I, Vaishali at Hajipur. These courts cited apprehensions about his potential association with criminal elements.

However, Justice Jha emphasized that such inferences must be based on hard facts, not mere suspicions. He criticized the lower courts for not considering the reformatory nature of the Juvenile Justice Act, which prioritizes the welfare and development of children. The judgment reiterated that the act's Section 12 mandates bail for juveniles unless their release poses a substantial risk of associating with criminals or endangers their well-being.

The court also noted that the petitioner’s father had pledged to ensure his son’s good behavior, a critical factor in the decision to grant bail. The ruling highlights the Juvenile Justice Act's focus on family responsibility and the principle of a fresh start, where a child's past records should not hinder their future, except in exceptional circumstances.

Justice Jha instructed that Banti Kumar be released on bail with conditions, including the presence of his father as a bailor and mandatory court appearances. This landmark decision not only provides relief to the petitioner but also reinforces the judiciary's commitment to child welfare and rehabilitation over punitive measures.

Bottom Line:

Juvenile Justice - Child in conflict with law - Bail application - Refusal of bail based on apprehension of association with bad elements and suspicion of involvement with gang - Held, without hard facts to substantiate such claims, inference cannot be made against the child - Principle of best interest of the child is paramount and gravity of offences is immaterial for granting bail under Juvenile Justice Act, 2015 - Bail granted upon undertaking by father to ensure good behavior of the child.

Statutory provision(s): Juvenile Justice (Care and Protection of Children) Act, 2015 Sections 3, 12

Banti Kumar @ Aryan Raj @ Hunter Yadav v. State of Bihar, (Patna) : Law Finder Doc Id # 2812328