Punjab & Haryana High Court Grants Bail to Juvenile Accused in Grenade Attack Case Under UAPA; Holds Poverty, Social Media Addiction and Peer Influence Alone Are Not Grounds to Deny Bail Under Section 12 of the JJ Act; Sets Aside Concurrent Rejection Orders

Case Name: Ankit Bedi @ Boxer v. State of Haryana

Date of Judgment: 06 July 2026

Citation: CRR-1519-2026

Bench: Hon’ble Mr. Justice Vinod S. Bhardwaj and Hon’ble Ms. Justice Sukhvinder Kaur.

Held: The Punjab and Haryana High Court held that a child in conflict with law is ordinarily entitled to bail under Section 12 of the Juvenile Justice (Care and Protection of Children) Act, 2015 unless the prosecution establishes the existence of any of the statutory exceptions contained therein. The Court ruled that factors such as poverty, excessive use of social media, susceptibility to peer influence, or the death of one parent cannot, by themselves, justify denial of bail in the absence of objective material demonstrating that the juvenile’s release would expose him to moral, physical or psychological danger, bring him into association with known criminals, or defeat the ends of justice. The Court further held that mere apprehensions or assumptions unsupported by evidence cannot override the statutory presumption in favour of granting bail to a juvenile, even where allegations under the Unlawful Activities (Prevention) Act, 1967 are involved.

Summary: The revision petition challenged concurrent orders of the Juvenile Justice Board, Kaithal and the Additional Sessions Judge-cum-Children Court refusing bail to a juvenile accused in a case arising from an alleged grenade attack on a police naka, for which offences under the Bharatiya Nyaya Sanhita, the Explosive Act, 1884 and the Unlawful Activities (Prevention) Act, 1967 had been invoked. The prosecution alleged that a social media post issued in the name of Babbar Khalsa claimed responsibility for the blast. The Juvenile Justice Board declined bail primarily on the basis of the Social Investigation Report, which recorded that the petitioner belonged to a Below Poverty Line family, was addicted to social media, was influenced by his peer group and that his deceased father’s alleged links with Khalistan Jindabad Force created an apprehension that the petitioner might again engage in unlawful activities if released. The appellate court affirmed this reasoning. The High Court found that these conclusions were founded on conjectures rather than objective evidence. It observed that the Social Investigation Report did not establish any nexus between the petitioner and any terrorist organisation or unlawful activity, nor did it disclose any material showing that his release would expose him to physical, psychological or moral danger or defeat the ends of justice. The Court also noted that the petitioner had no criminal antecedents, had already remained in custody for more than one year, and that the State itself was unable to produce any objective material linking him with any unlawful organisation. Reiterating the beneficial object of the Juvenile Justice Act, the Court held that the statutory mandate under Section 12 had not been satisfied and that the reasons assigned by the courts below were legally insufficient to deny bail to a child in conflict with law.

Decision: The Criminal Revision was allowed. The Punjab and Haryana High Court set aside the orders of the Juvenile Justice Board and the Children Court refusing bail and directed the release of the juvenile petitioner on regular bail.