Juvenility under amended juvenile law applies by offence date, and pending claims may be raised at any stage.

Juvenility in pending proceedings must be determined under the amended Juvenile Justice (Care and Protection of Children) Act, 2000 with reference to the date of the offence, and the claim may be raised at any stage. The Act's rehabilitative, child-centric scheme enlarges juvenile status to persons below eighteen years, and the age-determination procedure under the 2007 Rules applies to pending matters. Applying the beneficial interpretation owed to borderline cases, the appellant was held entitled to juvenile treatment despite being beyond sixteen under the 1986 Act, the High Court's view was set aside, and the matter was remitted to the Juvenile Justice Board.

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Issues: Whether the appellant was entitled to be treated as a juvenile on the date of the offence under the Juvenile Justice (Care and Protection of Children) Act, 2000, despite having crossed sixteen years under the Juvenile Justice Act, 1986; and whether the amended provisions, including the age-determination framework, applied to the pending proceedings.

Analysis: The statutory scheme of the Juvenile Justice (Care and Protection of Children) Act, 2000 was held to be rehabilitative and child-centric, with the definition of a juvenile enlarged to a person who had not completed eighteen years of age. The later amendments introducing Section 7-A, the amended Section 2(l), the proviso and Explanation to Section 20, and the age-determination procedure in Rule 12 of the Juvenile Justice (Care and Protection of Children) Rules, 2007, were treated as clarifying that juvenility may be claimed at any stage and must be determined with reference to the date of commission of the offence in pending matters. The Court also applied the settled principle that borderline cases should not be approached hypertechnically and that the beneficial statutory regime must be given full effect.

Conclusion: The appellant was held to be a juvenile, and the provisions of the Juvenile Justice (Care and Protection of Children) Act, 2000 applied to his case.

Final Conclusion: The High Court's view was set aside, the appeal succeeded, and the matter was sent back to the Juvenile Justice Board for decision in accordance with the applicable juvenile justice law.

Ratio Decidendi: In pending proceedings, a claim of juvenility must be determined under the amended juvenile justice law on the basis of the age on the date of the offence, and a person who had not completed eighteen years on that date is entitled to the Act's protective regime even if he was treated as non-juvenile under the earlier law.

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