LLM Practical training: Supreme court Judgments applying differential Association and Anomie Theories in Understanding Juvenile Delinquency in India

1. “Inherited Crime”: Om Prakash v. Union of India (2025)

Citation: Criminal Appeal No. 4229 of 2024 (arising from SLP(Crl.) No. 2214 of 2022)

Bench: Justices M.M. Sundresh & Aravind Kumar | Date: Jan 8, 2025

Facts:

At age 14, Om Prakash allegedly committed culpable homicide in 1994. His juvenility pleas were repeatedly rejected, and he spent 25 years imprisoned before the Supreme Court intervened.

Theory Application (Differential Association):

• “A child is not responsible for an act of crime, but is rather victimized by it. Such a child is nothing but an inheritor of crime”.

• Juvenile behavior arises from “socio-economic, political and cultural background, and life experience”.

• Deviant conduct reflects “exposure to a given environment” and “rampant inequality”.

Key Insight:

This judgment validates Edwin Sutherland’s premise that criminality is learned through intimate group interactions rather than born in the individual.

2. “Broken Norms, Broken Lives”: Pinki v. State of Uttar Pradesh (2025)

Citation: 2025 INSC 482

Bench: Justices J.B. Pardiwala & R. Mahadevan | Date: Apr 15, 2025

Facts:

An interstate child‐trafficking syndicate abducted impoverished children in Varanasi, selling them under the guise of adoption. The High Court granted bail to 13 accused, many of whom absconded.

Theory Application (Anomie Theory):

• Trafficking flourishes where “children are kidnapped and then trafficked for sale under the garb of adoption”.

• Institutional failures—“corruption, pressure from superiors/politicians and lack of review mechanism”—fuel normlessness.

• Victims largely hail from “vulnerable and impoverished backgrounds”.

Key Insight:

Reflecting Robert Merton’s strain theory, the Court spotlighted how social breakdown and blocked legitimate opportunities drive organized crime targeting children.

3. “Protect to Reform”: Salil Bali v. Union of India (2013)

Citation: Writ Petition (Criminal) No. 6 of 2013

Bench: Five-Judge Constitution Bench | Date: Jul 17, 2013

Facts:

Following public outrage over the Delhi gang-rape case, eight petitions sought to lower juvenile age from 18 to 16 so that serious young offenders could face adult trials.

Theory Integration:

• Differential Association: Emphasized rehabilitation over punishment, recognizing that juveniles learn criminal conduct from their environment.

• Anomie Theory: Preserved the 18-year threshold to maintain protective norms and prevent further societal strain.

• Constitution “guarantees several rights to children” and demands special protective measures under international standards.

Key Insight:

This landmark decision integrates both theories, underscoring that effective juvenile justice systems must address learned behaviors and combat structural strain through holistic rehabilitation.

Conclusion: Theory Informs Practice

These three case studies demonstrate the Supreme Court’s shift toward theory-informed reasoning in juvenile justice. By applying Differential Association and Anomie frameworks, the Court acknowledges that:

• Environment matters: Criminal conduct among youth is shaped by social learning.

• Structures matter: Institutional breakdown fosters lawlessness and exploitation.

• Responses must be holistic: Rehabilitation, not retribution, aligns with both criminological insights and constitutional mandates.

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