Supreme Court: Conviction under JJ Act is Not Vitiated Because Regular Court Tried Juvenile As Adult, But Sentence Cannot Operate

Section 20 specifically addresses proceedings pending before a regular court. It authorises the court to record or maintain a

finding that the juvenile committed the offence, but prohibits an

adult sentence and requires the matter to be dealt with under the

juvenile justice framework. The Explanation, introduced by the

2006 amendment, makes the benefit applicable to pending trials,

appeals, revisions and other criminal proceedings even where

the person has crossed the age of eighteen. The saving provision

in Section 25 of the Juvenile Justice (Care and Protection of

Children) Act, 2015 preserves the application of the earlier law

to proceedings already pending. {Para 25}

26. The statutory position is settled by Hari Ram v. State of Rajasthan (2009) 13 SCC 211; Dharambir v. State (NCT of Delhi) (2010) 5 SCC 344; and Jitendra Singh @ Babboo Singh v. State of U.P. (2013) 11 SCC 193, whereby this Court recognized that a person below eighteen on the date of an offence committed even before 1st April, 2001 receives the benefit of the 2000 Act; This Court further held that a conviction on merits need not be annulled merely because the person was tried by a regular court; and however the adult sentence cannot survive.

 NON-REPORTABLE

IN THE SUPREME COURT OF INDIA

CRIMINAL APPELLATE JURISDICTION

CRIMINAL APPEAL NO. 64 OF 2011

DINESH KUMAR Vs THE STATE OF HARYANA 

Author: ARAVIND KUMAR. J.

Citation: 2026 INSC 842.

Dated: AUGUST 12th , 2026.

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Supreme Court explain pre-requisite for filing common appeal Against Common Judgment Deciding Suit & Counterclaim

 Finding no contrary or restrictive provisions in the CPC,

we hold and declare that a suit and a counterclaim, if

adjudicated by a single common judgment; both on the original

claim and on the counterclaim, it can be challenged in a

composite appeal. The composite appeal, however, should

show the grounds raised against the decree in the suit and the

decree in the counterclaim separately; whether there are two

decrees or one drawn up. The composite appeal should also be

valued as two separate appeals and the court fees paid

accordingly. This would enable the appeal to be considered on

merits, without the grounds of estoppel and res judicata raised

only for reason of two appeals not being filed. Though an

implied mandate could be drawn from the various provisions,

we are of the opinion that this would ensure avoidance of

procedural rigmarole as also multiplicity of litigations. {Para 29}

Reportable

IN THE SUPREME COURT OF INDIA

CIVIL APPELLATE JURISDICTION

Civil Appeal No. of 2026

(Arising out of SLP (C) No.4338 of 2025)

Basudev & Ors. Vs  Sanjay Kumar & Ors.

Author: K.Vinod Chandran, J.

Citation: 2026 INSC 831.

Dated: AUGUST 11, 2026.

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Supreme Court: Courts Should Adopt Liberal Approach In Condoning Delay In Appeals Filed By Convicts from jail

We are deeply dismayed, and equally perturbed by the

order which rejected an application seeking condonation of delay

of 3157 days and as a consequence dismissed the ‘Jail Memo of

Appeal’ against the order of conviction under Section 302, with

sentence imposed of life imprisonment where the convict had, at

the time of the impugned order suffered incarceration of 12 years

and now a further period of 10 years; a total of 22 years. {Para 2}

3. Access to justice still eludes the marginalized sections of our

society and especially those convicted and imprisoned from

amongst them. When the three pillars of democracy consistently

endeavor to bring legal aid to the doorsteps of every citizen,

especially the poor, the needy and the deprived, we, in the

Constitutional Courts should introspect to sensitize ourselves in

taking a liberal approach insofar as delay occasioned in filing an

appeal from an order of conviction and sentence, depriving a

person, the most valuable and fundamental of all rights; liberty.

Not a mere liberal approach but a pro-active one to condone

delay, however large it is when a convict knocks at the door of a

Court, in appeal, which in the present case raises some real

concerns. 

Reportable

IN THE SUPREME COURT OF INDIA

CRIMINAL APPELLATE JURISDICTION

Criminal Appeal No…………..of 2026

(@Special Leave Petition (Crl.) No.7128 of 2026)

Arjun Jani @ Tuntun Vs   State of Orissa

Author: K. VINOD CHANDRAN, J.

Citation: 2026 INSC 802

Dated: AUGUST 04, 2026.

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Supreme Court Explains Parameters To Decide Application For Additional Evidence under Order 41 Rule 27 CPC

 12. The decisions relied on by the Appellant can be captured and

summarised as follows:

12.1 An Appellate Court has a statutory duty to deal with an Application for Additional Evidence on its merits. The application cannot be ignored while the Court proceeds to pronounce the final Judgment. Jatinder Singh (supra)

12.2 The Application must be considered simultaneously with the hearing of the main Appeal on its merits to determine whether the Court "requires" the documents to pronounce Judgment or for any other substantial cause. North Eastern Railway Administration (supra)

12.3 The Appellate Court must pass a specific order either allowing or rejecting the application. If the production of documents is allowed, the Court is obligated to record its reasons for admission.

12.4 Before undertaking the exercise of evaluating the additional evidence, the Appellate Court must first examine the party's pleadings to ensure that the foundational case set up supports the introduction of the proposed evidence.

12.5 Dismissing an appeal without deciding a pending application for additional evidence constitutes a jurisdictional error and results in a severe miscarriage of justice.

NON-REPORTABLE

IN THE SUPREME COURT OF INDIA

CIVIL APPELLATE JURISDICTION

(@ SPECIAL LEAVE PETITION (CIVIL) DIARY NOS. 10525 OF 2026)

CHOWDAPPA Vs HANUMANTHARAYAPPA AND OTHERS 

Author: S.V.N. BHATTI, J.

Dated: August 6, 2026.

Citation: 2026 INSC 816

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