Say the ratio out loud before you open Reasoning — recalling it unprompted is exactly what the exam pays for.
Why it matters
Once juvenility can be claimed at any stage, everything turns on proof of age, and proof of age in India is rarely a birth certificate. The practical question in almost every juvenility problem is which school document will do.
Shah Nawaz answers that question, and it is the case to cite for the documentary route to age.
Facts
The question concerned the determination of the age of a person claiming to be a juvenile, and the documents on which that determination may rest.
Held
The Court held that a school leaving certificate and a marks sheet are also relevant documents for proof of age.
Reasoning
The determination of age is a question of fact to be decided on the best evidence available, and the rules governing it set out a hierarchy of documents rather than a single admissible instrument. A record made by a school in the ordinary course, before any question of juvenility arose and for a purpose unconnected with the criminal case, has exactly the qualities that make a document reliable on age. To reject it because it is not the matriculation certificate itself would push the inquiry towards medical opinion, which the hierarchy treats as the last resort precisely because it is the least precise.
Exam use
Use it in any problem in which the child's age is disputed and the only documents available are school records, and in any question on the machinery for age determination.
Set it inside the statutory hierarchy now in s. 94(2) of the Act of 2015, which is what an examiner will expect to see: first the date of birth certificate from the school, or the matriculation or equivalent certificate from the examination Board; in its absence, the birth certificate given by a corporation, municipal authority or panchayat; and only in the absence of both, an ossification test or other latest medical age-determination test, to be completed within fifteen days of the order. The age recorded is deemed for the purposes of the Act to be the true age.
It does not decide that a school record is conclusive, and it does not decide what happens when the documents conflict or are shown to be fabricated. On that, and on the limited role of medical evidence, take Kulai Ibrahim v. State.
The decision preceded the Act of 2015; cite it as authority on the documentary material, and give the current provision as s. 94.