Salil Bali v. Union of India

Facts

• PIL challenging the JJ Act 2000's fixing of 18 years as the upper limit for juvenility.
• Petitioner argued that 16-18 year olds committing heinous offences should not be shielded by the JJ Act.
• Scientific evidence on brain development was placed before the court.

Issue

1. Whether fixing 18 years as the age of juvenility discriminates against victims by giving lenient treatment to near-adult offenders.

Held

• The 18-year threshold is based on scientific evidence: prefrontal cortex (responsible for judgment, impulse control) is not fully developed until early-to-mid twenties.
• UNCRC Art. 1 defines a child as below 18; India ratified UNCRC in 1992.
• The classification is not arbitrary under Art. 14; it has rational nexus to the reformative objective.
• Victims' rights do not require adult punishment for children; rehabilitation serves long-term societal interest.
• The legislature is competent to determine the age threshold based on policy.

Ratio Decidendi

Adolescent brain research shows that decision-making capacity, risk assessment, and impulse control are developmentally incomplete in the 14-18 age group. A justice system that treats adolescents as fully responsible adults ignores scientific reality. The reformative approach for this age group is both scientifically justified and constitutionally valid.