Juvenile status and pending proceedings under juvenile justice law are governed by the offence date and the later beneficial statute.

The Supreme Court interpreted juvenile justice legislation as beneficial social welfare law requiring a liberal construction to advance care, protection and rehabilitation of juveniles. It held that juvenile status must be assessed by reference to the date of the alleged offence, not the date of production before the court or competent authority, and treated the earlier three-Judge Bench view as correct. It further held that proceedings initiated under the Juvenile Justice Act, 1986 and still pending when the Juvenile Justice (Care and Protection) Act, 2000 commenced are governed by the 2000 Act if the person had not completed 18 years on that date.

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Issues: (i) Whether the age of an alleged juvenile offender is to be determined with reference to the date of occurrence of the offence or the date of production before the court or competent authority; (ii) Whether proceedings initiated under the Juvenile Justice Act, 1986 and pending on the commencement of the Juvenile Justice (Care and Protection) Act, 2000 are governed by the 2000 Act.

Issue (i): Whether the age of an alleged juvenile offender is to be determined with reference to the date of occurrence of the offence or the date of production before the court or competent authority.

Analysis: The Act was held to be a beneficial social welfare legislation intended to secure care, protection, treatment, development and rehabilitation of juveniles, and therefore required a liberal construction advancing its object. Reading the definitions, the provisions governing bail and custody, and the provisions relating to presumption and determination of age together, the relevant inquiry was held to relate back to the date on which the offence was allegedly committed. The contrary view that the date of production before the authority or court controls was rejected, and the earlier three-Judge Bench view was treated as the correct law.

Conclusion: The reckoning date is the date of occurrence of the offence, not the date of production before the court or competent authority.

Issue (ii): Whether proceedings initiated under the Juvenile Justice Act, 1986 and pending on the commencement of the Juvenile Justice (Care and Protection) Act, 2000 are governed by the 2000 Act.

Analysis: The repeal-and-savings provision, the special provision for pending cases, the enlarged definition of juvenile, and the continuation-of-inquiry provision were read together to hold that pending proceedings are not excluded from the benefit of the 2000 Act. The statutory scheme was taken to show that a person who had not completed eighteen years on the date the 2000 Act came into force could claim its benefit even in proceedings that had originated under the 1986 Act and were still pending.

Conclusion: The 2000 Act applies to pending proceedings initiated under the 1986 Act, provided the person had not completed 18 years of age on 1 April 2001.

Final Conclusion: The decision settles both the reckoning date for juvenile status and the retrospective reach of the 2000 juvenile justice regime in pending matters, and the appeal succeeded on both questions.

Ratio Decidendi: For determining juvenile status under the protective juvenile justice legislation, the relevant date is the date of the offence, and pending proceedings continue under the later beneficial statute if the person was below the statutory upper age limit on its commencement.

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