Juvenile Justice classification of offences: only offences with a minimum seven-year punishment qualify as heinous.

The Juvenile Justice Act's definition of "heinous offences" under Section 2(33) is confined to offences carrying a minimum punishment of seven years or more. Offences with no minimum sentence, or with a minimum below seven years even if the maximum exceeds seven years, do not fall within that category. The Court declined to read out the word "minimum" or expand the definition by judicial rewriting, holding that any statutory gap must be addressed by the Legislature. Until legislative intervention, such offences are to be treated as serious offences under the Act.

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Issues: Whether an offence punishable with a maximum sentence of more than seven years but without a minimum sentence, or with a minimum sentence of less than seven years, falls within the meaning of "heinous offences" under Section 2(33) of the Juvenile Justice (Care and Protection of Children) Act, 2015.

Analysis: The definition of "heinous offences" in Section 2(33) is tied to offences carrying a minimum punishment of seven years or more. The categorisation of petty, serious and heinous offences under the Act forms part of a structured scheme in Sections 14, 15 and 19, under which a child in conflict with law is not automatically tried as an adult. The Court declined to delete the word "minimum" on the ground of surplusage, holding that the language of the provision was clear and that a perceived gap in the statute could not be filled by judicial rewriting. At the same time, the Court noted that the Act did not expressly deal with the fourth category of offences, namely those with no minimum sentence or with a minimum sentence below seven years but a maximum sentence above seven years.

Conclusion: Such offences do not fall within "heinous offences" under Section 2(33). They are to be treated as "serious offences" until the Legislature acts.

Final Conclusion: The appeal was disposed of by affirming that the disputed category is outside the definition of heinous offences, while directing that such cases be dealt with as serious offences under the Act until appropriate legislative intervention.

Ratio Decidendi: A statutory definition must be given effect according to its clear language, and a court cannot expand it by deleting an express qualifying word where the legislative intent is not unmistakably clear; any statutory gap must be left to the Legislature unless a limited constitutional direction is necessary.

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