Juvenile Bail: Courts Cannot Impose Onerous Conditions on Guardian, Says Supreme Court

The Supreme Court has held that courts should not impose onerous conditions on the guardian of a juvenile while granting bail, particularly conditions requiring payment of victim compensation when the proceedings are still pending. Court said such conditions cannot be justified merely because the accused is a juvenile and is being released in the care and supervision of a guardian.

A Bench of Justices Sanjay Kumar and Sanjeev Sachdeva set aside an order of the Jharkhand High Court, which had imposed conditions requiring the guardian of a juvenile to pay compensation to the victim and submit an undertaking regarding the juvenile’s future conduct.

Why did the Supreme Court set aside the bail conditions?

The Bench held that the high court was not justified in imposing such conditions on the guardian of the juvenile for grant of bail. It also held that there was no cause for awarding victim compensation at that stage, when the proceedings were still pending.

The appeal arose out of an order dated June 9, 2025, passed by a single judge of the Jharkhand High Court at Ranchi.

By the order, the high court had granted bail to the appellant in connection with an FIR registered on November 21, 2023, at Mahagama Police Station in Godda district, Jharkhand, for an offence punishable under Section 366A of the Indian Penal Code, 1860 (now Section 96 of the Bharatiya Nyaya Sanhita), subject to certain conditions.

The high court directed that the appellant be released on bail in the care and supervision of his elder brother, on furnishing bail bonds of Rs 15,000 with two sureties of the like amount each to the satisfaction of the In-charge Principal Magistrate of the Juvenile Justice Board, Godda.

However, it also imposed additional conditions on the juvenile’s guardian.

The guardian was directed to pay Rs 1,50,000 to the victim by way of victim compensation. The juvenile’s brother was also directed to file an undertaking before the court below that the juvenile would not indulge in such a crime in future.

The high court further said that in case of violation of the condition, the prosecution would be at liberty to take steps for cancellation of bail.

The juvenile’s brother was also directed to submit his mobile number before the court below, keep it active and not change it during the pendency of the case without prior permission of the court. He was also required to produce the juvenile whenever required.

Supreme Court suspends onerous bail conditions

On October 16, 2025, the Supreme Court had suspended the conditions imposed by the High Court.

Court also issued notice to the victim’s father, who, however, chose not to appear.

"Having heard the counsel for the appearing parties, we are of the opinion that the high court was not justified in imposing conditions upon the guardian of the juvenile for grant of relief, on the ground that he was a juvenile. Further, no cause was made out for grant of victim compensation at that stage, that is, during the pendency of the proceedings," the Bench said.

The Supreme Court clarified that if there is any violation of the other bail conditions, apart from those challenged before it, the State or the victim’s family would remain free to seek cancellation of bail.

Court accordingly allowed the appeal and set aside the impugned conditions, while leaving it open to the concerned parties to take such measures as may be warranted.

Case Title: Chandan Kumar Ravidas @ Chandan Kumar Vs State of Jharkhand 

Bench: Justices Sanjay Kumar and Sanjeev Sachdeva

Date of Judgment: July 22, 2026