📖 Rattan Lal v. State of Punjab, AIR 1965 SC 444; (1964) 7 SCR 676

Facts: A boy of sixteen was convicted of house trespass and outraging the modesty of a young girl and sentenced to imprisonment. After his conviction by the trial court, the Act was brought into force in the district.

Issue: Could an appellate or revisional court apply the Act to a case in which it was not in force when the offence was committed or when the trial court decided it?

Held: The majority held that the Act, as a beneficial measure reflecting the modern liberal trend in penology, could be applied by the appellate or revisional court. An ex post facto law that benefits the accused is not barred by Article 20(1). The Court described the Act as a milestone in the progress of the modern liberal trend of reform in the field of penology.

Ratio: The Act operates retrospectively in the offender's favour, and appellate courts must consider it in pending cases.

Exam use: Cite for the reformative object of the Act, for beneficial construction, and for the proposition that Article 20(1) does not bar retrospective beneficial laws.

📖 Ramji Missar v. State of Bihar, AIR 1963 SC 1088

Facts: The appellant was under twenty-one when the trial court found him guilty, but had crossed that age by the time his appeal was heard.

Issue: For Section 6, is the offender's age taken at the date of the trial court's finding, or at the date the appellate court decides?

Held: The object of Section 6 is to prevent young offenders from becoming criminals through contact with hardened offenders in prison. The relevant age is the age on the date the trial court found the offender guilty, and the appellate court must apply Section 6 by reference to that date, even if the offender is over twenty-one by the time of the appeal.

Ratio: Age for Section 6 is fixed at the trial court's finding of guilt; later ageing during appeal does not defeat it.

Exam use: The starting point on the relevant date for Section 6, later confirmed in Sudesh Kumar (2008).

📖 Sarju Prasad v. State of Bihar, AIR 1965 SC 843 (decided 20 August 1964)

Facts: The appellant and another attacked two men with a knife in a busy public place in daylight. The injuries did not damage vital organs. He was convicted of attempt to murder under Section 307 IPC. He was under twenty-one.

Issue: Was the offence attempt to murder, and if not, how must a young offender be sentenced?

Held: A Bench of A.K. Sarkar, Raghubar Dayal and J.R. Mudholkar, JJ. held that the prosecution had not proved the intention or knowledge required for Section 307, and altered the conviction to voluntarily causing hurt with a dangerous weapon under Section 324. Since the appellant was under twenty-one and the offence was now one punishable with imprisonment but not life, Section 6 applied, and the case was sent back to the High Court to deal with him in accordance with the Act.

Ratio: Once the conviction is for an offence within Section 6, a young offender cannot be sentenced to imprisonment without the court following Section 6.

Exam use: Shows how altering a conviction can bring Section 6 into play, and that the Supreme Court will remit the case for proper sentencing under the Act.

📖 Daulat Ram v. State of Haryana, AIR 1972 SC 2434

Facts: The appellant, who was under twenty-one, and his father were convicted of causing grievous hurt and hurt under Sections 325 and 323 read with Section 34 IPC for assaulting a woman, and sentenced to imprisonment. The courts below had not dealt with Section 6.

Issue: Must an appellate court apply Section 6 where the courts below have failed to consider it?

Held: A Bench of Shelat, Dua and Khanna, JJ. held that Section 6 restricts the imprisonment of offenders under twenty-one and that appellate courts are bound to give effect to it. The Court released the appellant on probation of good conduct instead of confirming the sentence of imprisonment.

Ratio: The duty under Section 6, including the requirement to consider release and obtain the probation officer's report, binds appellate courts, including the Supreme Court.

Exam use: Cite for the mandatory character of Section 6 at every level, alongside Lakhvir Singh (2021).

📖 Ved Prakash v. State of Haryana, (1981) 1 SCC 447 (decided 12 November 1980)

Facts: A young man from an agricultural family, with no previous record, was convicted of an offence in which a firearm was used, arising out of a land dispute.

Issue: What is the sentencing court's duty where probation may be available to a young first offender?

Held: Krishna Iyer and Venkataramiah, JJ. held that sentencing is a sensitive exercise of discretion, not a routine or mechanical prescription. The court must collect material on the offender's social background and must consider the Probation Act. The appellant was released under Section 4(1) on a three-year bond with two sureties, one of them his father, with supervision by a probation officer for one year and a condition that he not consume alcohol.

Ratio: The court has a duty of its own to gather social material and consider probation, whether or not the parties raise it.

Exam use: The leading case on the sentencing court's duty to consider probation, and a model probation order with supervision and conditions.

📖 Sudesh Kumar v. State of Uttarakhand, 2008 INSC 113 (decided 29 January 2008)

Facts: The appellant, convicted of robbery and under the Arms Act, claimed Section 6 on the ground that he was under twenty-one when he committed the offence.

Issue: Is the relevant age for Section 6 the age at the offence or the age at sentence?

Held: C.K. Thakker and P.P. Naolekar, JJ., following Ramji Missar, held that the relevant age is the age on the date of sentence. Since the appellant was over twenty-one when sentenced, Section 6 did not apply. A plea of age should be raised before the trial court.

Ratio: Age at sentencing, not age at the offence, governs Section 6.

Exam use: Contrast with the Juvenile Justice Act, where the date of the offence governs (Pratap Singh, 2005).