State of Kerala v. Sirajudeen (Age Determination)
Kerala High Court2026 SCC OnLine Ker 786Bench: J. A. Muhamed Mustaque, J. Shoba Annamma Eapen
The Kerala High Court held that Section 34 POCSO and Rule 12 of the Juvenile Justice Rules (as applicable to age determination in child-related matters) establish a clear hierarchy of evidence for age determination: (1) birth certificate from a corporation/municipality, (2) school admission register entry or school transfer certificate, (3) matriculation certificate — all preferred over (4) medical opinion. Ossification tests have a known margin of error of 3–5 years and are unreliable for adolescents in the 14–19 age range. They are a last resort when no documentary evidence exists, not an alternative route where documents are available and consistent. Three concordant documents showing age 15 cannot be displaced by an inconclusive ossification test range. The trial court's order for ossification test, in the face of consistent documents, was erroneous. The POCSO trial was directed to proceed treating the victim as a child at the time of offence.