Arbitration and Conciliation Act, 1996 — Ss. 5, 34, 37 Scope of judicial interference — Appellate jurisdiction under S. 37 — Held, no wider than S. 34 — Reappreciation of evidence and re-interpretation of contract impermissible. The jurisdiction of the Appellate Court under Section 37 of the Act is strictly circumscribed and is co-extensive with, and not wider than, the jurisdiction under Section 34. Where an arbitral award has been upheld under Section 34, the Appellate Court cannot interfere merely by adopting a different interpretation of contractual clauses or by reassessing the merits of the claim. (Paras 22, 30–37, 38–40, 50–52)

Arbitration and Conciliation Act, 1996 — Ss. 5, 34, 37

Scope of judicial interference — Appellate jurisdiction under S. 37 — Held, no wider than S. 34 — Reappreciation of evidence and re-interpretation of contract impermissible.

The jurisdiction of the Appellate Court under Section 37 of the Act is strictly circumscribed and is co-extensive with, and not wider than, the jurisdiction under Section 34. Where an arbitral award has been upheld under Section 34, the Appellate Court cannot interfere merely by adopting a different interpretation of contractual clauses or by reassessing the merits of the claim.
(Paras 22, 30–37, 38–40, 50–52)

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Arbitral award — Interpretation of contract — Finality

Construction of contractual clauses is within exclusive domain of arbitral tribunal — Courts cannot substitute their own interpretation.

If the Arbitral Tribunal has taken a plausible and reasonable view in interpreting the terms of the contract, and such interpretation has been accepted by the court under Section 34, the same cannot be substituted or varied by the Appellate Court under Section 37 merely because another view is possible.
(Paras 20, 29–31, 38–40, 46–48)

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Idle time compensation — Dredging contract — Backhoe Dredger (BHD)

Claim for idle charges — Not confined to “major dredgers” — Conjoint reading of contractual clauses.

Clause 38 of the Licence Agreement, though referring to idle time charges for major dredgers, does not prohibit payment of idle time compensation for other equipment. On a conjoint reading of Clauses 38, 41.1, 41.2 and 51.1, idle time compensation is admissible for equipment including a Backhoe Dredger, where idling results from failure to provide timely access to site or interruptions contemplated under the contract.
(Paras 42–46, 49)

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Patent illegality — Public policy — Ss. 34 & 37

Speaking award — No patent illegality — Interference unwarranted.

Where the arbitral award is a reasoned award, supported by interpretation of contractual clauses and evidence, and does not violate any substantive provision of law, fundamental policy of Indian law, or basic notions of morality or justice, it cannot be interfered with under Sections 34 or 37 of the Act.
(Paras 27–29, 41, 47–48)

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Arbitration jurisprudence — Minimal court intervention

Object of Act reaffirmed — Excessive appellate scrutiny defeats arbitration.

The Arbitration and Conciliation Act, 1996 is a special enactment aimed at expeditious resolution of commercial disputes with minimal judicial intervention. Multi-tiered scrutiny of arbitral awards on merits frustrates the legislative intent and must be eschewed.
(Paras 24–26, 51)

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ANALYSIS (Issue-wise with Paragraph References)

I. Core Issue: Limits of Section 37 Jurisdiction (Paras 22, 30–37)

The Supreme Court identifies the decisive question as whether the Division Bench was justified in interfering under Section 37 after the arbitral award had already been upheld under Section 34. Relying on a consistent line of precedent, the Court reiterates that Section 37 does not confer ordinary appellate powers and does not permit re-examination of the merits of the arbitral award.

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II. Finality of Arbitral Interpretation (Paras 29–31, 38–40)

The Arbitral Tribunal had interpreted the Licence Agreement and concluded that idle time compensation for the Backhoe Dredger was contractually permissible. This interpretation was accepted by the Single Judge under Section 34. The Supreme Court holds that once such acceptance occurs, the Appellate Court is bound by that interpretation and cannot substitute its own.

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III. Patent Illegality and Public Policy Threshold (Paras 27–29, 41)

The Court clarifies that the respondent’s challenge was not founded on any recognised ground under Section 34, such as patent illegality or violation of public policy. The award was reasoned, speaking, and based on contractual construction. Hence, interference was legally impermissible.

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IV. Contractual Clauses on Idle Time Compensation (Paras 42–46)

A detailed conjoint reading of Clauses 38, 41.1, 41.2 and 51.1 demonstrates that:

• Clause 38 does not exclude idle time compensation for non-major dredgers;

• Clauses 41.1 and 41.2 contemplate consequences of failure to give possession;

• Clause 51.1 expressly provides for idle time compensation due to interruptions.
  The Tribunal’s conclusion was therefore a plausible contractual interpretation.

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V. Ancillary Issues — Minor vs. Major Dredger (Para 49)

The Court holds that the debate on whether the Backhoe Dredger was a major or minor dredger is ultimately irrelevant, as the Licence Agreement permitted deployment of such equipment and did not bar compensation for its idling.

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VI. Error of the Division Bench (Paras 38, 50–52)

The Division Bench exceeded its jurisdiction by re-interpreting contractual clauses and disturbing a concurrent finding of the Arbitral Tribunal and the Single Judge. This amounted to an impermissible appellate reassessment of merits.

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RATIO DECIDENDI

An Appellate Court exercising jurisdiction under Section 37 of the Arbitration and Conciliation Act, 1996 cannot interfere with an arbitral award that has been upheld under Section 34 by re-appreciating evidence or re-interpreting contractual terms; where the arbitral tribunal has adopted a plausible interpretation and the award is not vitiated by patent illegality or public policy violation, judicial interference is impermissible.

A quasi-judicial body such as the Company Law Board has no power to condone delay under Section 58(3) of the Companies Act, 2013 in the absence of an express statutory provision applying Section 5 of the Limitation Act, 1963; the principles underlying Section 5 cannot be imported by analogy, inherent powers, or retrospective application of Section 433.

Companies Act, 2013 — Ss. 58(3), 433 — Limitation Act, 1963 — S. 5 — Company Law Board (CLB)

Condonation of delay — Power of quasi-judicial body — Absence of statutory conferment — Held, CLB has no power to condone delay under S. 58(3) of the Companies Act, 2013 prior to enforcement of S. 433.

The Company Law Board, being a quasi-judicial authority and not a “court”, cannot apply Section 5 of the Limitation Act, 1963 in the absence of express statutory empowerment. During the interregnum period between 12-09-2013 and 01-06-2016, no provision analogous to Section 433 of the Companies Act, 2013 existed to confer such power on the CLB.
(Paras 33–41, 51–58, 90–93)

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Limitation Act, 1963 — Applicability — Courts vs. Tribunals

Limitation Act applies only to courts unless expressly extended — Long-settled principle reaffirmed.

The Limitation Act, 1963 applies only to courts and not to tribunals or quasi-judicial bodies, unless the statute expressly provides otherwise. The CLB was vested with limited powers under Section 10E(4C) of the Companies Act, 1956, which did not include the power to condone delay.
(Paras 42–52, 56–58)

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Limitation Act, 1963 — Ss. 5 & 14 — Distinction

Principles of S. 14 may apply to tribunals — Principles of S. 5 cannot — Conceptual and functional distinction explained.

While principles underlying Section 14 (exclusion of time) may be applied to quasi-judicial bodies to advance justice, Section 5 (extension of time) involves discretionary alteration of the limitation period and can be exercised only by courts or by tribunals expressly empowered by statute.
(Paras 59–65, 66–85)

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Companies Act, 2013 — S. 433 — Prospective operation

Application of Limitation Act to NCLT/NCLAT — Not retrospective — Cannot validate earlier CLB orders.

Section 433 of the Companies Act, 2013, which applies the Limitation Act to proceedings before the NCLT and NCLAT, came into force only on 01-06-2016. It cannot be given retrospective effect so as to confer jurisdiction retrospectively upon the CLB to condone delay.
(Paras 36–41, 52, 90–93)

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Inherent powers — CLB Regulations, 1991 — Reg. 44

Inherent power cannot override statutory limitation.

The inherent powers saved under Regulation 44 of the CLB Regulations cannot be invoked to defeat or circumvent a mandatory statutory limitation period. There is no inherent power to condone delay.
(Paras 99–102)

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ANALYSIS (Issue-wise with Paragraph Mapping)

I. Statutory Interregnum and Forum Competence (Paras 33–41)

The Court undertakes a detailed examination of the phased enforcement of the Companies Act, 2013. Although Section 58 came into force on 12-09-2013, the adjudicatory forum continued to be the CLB until the constitution of the NCLT on 01-06-2016. Crucially, during this period, no statutory provision extended the Limitation Act to the CLB.

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II. CLB Not a “Court” for Limitation Purposes (Paras 42–52)

Relying on a consistent line of authority (Athani Municipal Council, Kunhaliumma, Parson Tools, M.P. Steel), the Court reiterates that limitation provisions apply forum-wise. The CLB, being a tribunal with limited civil-court powers, does not qualify as a “court” for invoking Sections 4–24 of the Limitation Act.

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III. Inapplicability of Section 5, Limitation Act (Paras 53–58)

Section 5 involves discretionary enlargement of limitation. Such discretion can only be exercised where expressly conferred. The Court holds that neither Section 10E of the 1956 Act nor Section 58 of the 2013 Act confers such power on the CLB.

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IV. Critical Distinction Between Sections 5 and 14 (Paras 66–85)

This judgment provides a comprehensive doctrinal exposition:

• Section 5: Extension of limitation; discretionary; alters vested rights.

• Section 14: Exclusion of time; mandatory; restores litigant to a lawful position.

Only the latter’s principles may be applied by tribunals in the absence of express exclusion. This distinction is central to rejecting the respondent’s reliance on M.P. Steel.

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V. Section 433 — No Retrospective Cure (Paras 90–93)

The High Court’s reasoning that Section 433 could be applied retrospectively is rejected. Jurisdictional competence must exist on the date of the original order. Subsequent legislative empowerment cannot validate an earlier act done without jurisdiction.

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VI. Inherent Powers Misapplied (Paras 99–102)

The CLB’s reliance on Regulation 44 is held to be legally untenable. Inherent powers are procedural, not substantive, and cannot be exercised to override express or implied statutory bars.

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RATIO DECIDENDI

A quasi-judicial body such as the Company Law Board has no power to condone delay under Section 58(3) of the Companies Act, 2013 in the absence of an express statutory provision applying Section 5 of the Limitation Act, 1963; the principles underlying Section 5 cannot be imported by analogy, inherent powers, or retrospective application of Section 433.

Quashing of criminal proceedings – Scope and limits While exercising inherent jurisdiction under Section 482 CrPC, the High Court is required to examine only whether the uncontroverted allegations, taken at their face value, disclose commission of a cognizable offence. The High Court cannot conduct a roving inquiry, assess credibility of allegations, or record findings on disputed facts. (Paras 21–24, 30–31) Indian Penal Code, 1860 – Sections 417, 420, 465, 468, 471, 120B Forgery and cheating – Prima facie allegations – Trial required Where the complaint alleges abuse of authority, fraudulent execution and use of documents, and dishonest intention at the inception of the transaction, the ingredients of offences relating to cheating and forgery are prima facie disclosed, warranting trial.

Code of Criminal Procedure, 1973 – Section 482

Quashing of criminal proceedings – Scope and limits

While exercising inherent jurisdiction under Section 482 CrPC, the High Court is required to examine only whether the uncontroverted allegations, taken at their face value, disclose commission of a cognizable offence. The High Court cannot conduct a roving inquiry, assess credibility of allegations, or record findings on disputed facts.
(Paras 21–24, 30–31)

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Indian Penal Code, 1860 – Sections 417, 420, 465, 468, 471, 120B

Forgery and cheating – Prima facie allegations – Trial required

Where the complaint alleges abuse of authority, fraudulent execution and use of documents, and dishonest intention at the inception of the transaction, the ingredients of offences relating to cheating and forgery are prima facie disclosed, warranting trial.
(Paras 25, 31)

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Civil dispute and criminal liability – Co-existence

The existence, pendency, or even adjudication of civil proceedings on the same subject-matter does not bar criminal prosecution when the allegations disclose criminal intent and offences under the IPC.
(Paras 26–28)

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Section 482 CrPC – Effect of civil court findings

Findings in civil proceedings upholding the validity of documents are not determinative of criminal culpability at the stage of quashment, particularly when issues of mens rea, forgery, or deception were not adjudicated in the civil suit.
(Paras 26–27)

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Delay in lodging complaint – Effect

Delay in initiating criminal proceedings by itself is not a ground for quashing at the threshold. Whether the delay is explained or affects the credibility of prosecution is a matter for appreciation at trial.
(Para 30)

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Abuse of process – High Court’s approach

Quashing criminal proceedings solely on the basis of conduct of the complainant, alleged suppression of facts, or delay amounts to exceeding jurisdiction under Section 482 CrPC, when the FIR discloses a prima facie offence.
(Paras 29–31)

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ANALYSIS

1. Nature of the dispute

The criminal proceedings arise from allegations of fraud, cheating, and forgery relating to three registered settlement deeds executed during the lifetime of the original owners, allegedly by abusing their advanced age and vulnerability.
(Paras 4–8, 25)

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2. High Court’s reasoning

The High Court quashed the proceedings primarily on the grounds that:

• the dispute was civil in nature,

• settlement deeds had been upheld in a civil suit,

• the appellant remained ex parte in civil proceedings, and

• there was delay in lodging the criminal complaint.
  (Paras 12, 29)

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3. Supreme Court’s scrutiny

The Supreme Court held that the High Court travelled beyond permissible limits of Section 482 CrPC by:

• evaluating the conduct of the complainant,

• drawing adverse inferences from delay, and

• treating civil adjudication as conclusive of criminal liability.
  (Paras 24, 29–30)

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4. Civil and criminal proceedings distinguished

The Court reiterated that civil and criminal proceedings operate in distinct domains, and that adjudication of civil rights does not preclude criminal prosecution when allegations of fraud and forgery exist.
(Paras 26–28)

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5. Necessity of trial

Issues relating to mental state of executants, misuse of power of attorney, existence of dishonest intent, and use of allegedly forged documents require full-fledged trial on evidence, and cannot be summarily decided under Section 482 CrPC.
(Para 31)

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RATIO DECIDENDI

1. High Courts, while exercising inherent jurisdiction under Section 482 CrPC, must confine themselves to examining whether the allegations in the FIR or complaint, taken at face value, disclose commission of a cognizable offence, without assessing credibility or disputed facts.

2. Civil proceedings and criminal prosecution can coexist; civil adjudication upholding the validity of documents does not, by itself, bar prosecution for offences such as cheating or forgery.

3. Delay in filing a criminal complaint, or the complainant’s conduct in related civil proceedings, cannot be treated as grounds for quashing criminal proceedings at the threshold.

4. Where allegations disclose fraudulent intent, misuse of authority, and fabrication or use of forged documents, criminal proceedings must be allowed to proceed to trial.

A single fatal blow inflicted with a blunt weapon during a sudden quarrel, without premeditation, attracts Section 304 Part II IPC when the accused acts with knowledge of likely death but without intention to kill. In a free fight with injuries on both sides, absence of prior concert or meeting of minds negates common object under Section 149 IPC. Medical evidence corroborating ocular testimony regarding a fatal head injury is sufficient to sustain conviction under Section 304 Part II IPC. Advanced age of the accused, long lapse of time since the offence, and substantial incarceration already undergone justify reduction of sentence to the period already served, without disturbing the conviction.

Indian Penal Code, 1860 – Sections 299, 300, 304 Part II

Culpable homicide not amounting to murder – Single blow – Knowledge without intention

Where death is caused by a single blow with a blunt weapon during a sudden quarrel and free fight, without premeditation, and the circumstances indicate knowledge that the act was likely to cause death but no intention to cause death, the offence falls under Section 304 Part II IPC, and not under Section 302 IPC.
(Paras 5.1–5.1.5, 5.4–5.6)

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Indian Penal Code, 1860 – Sections 147, 148, 149

Unlawful assembly – Common object – Not established

In a free fight arising out of a sudden quarrel, where both sides sustain injuries and there is no evidence of prior meeting of minds, common object under Section 149 IPC is not established, and conviction under Sections 147, 148, and 149 IPC is unsustainable.
(Paras 5.2–5.2.1)

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Evidence – Ocular and medical evidence

Single head injury – Corroboration

Conviction under Section 304 Part II IPC can be sustained where ocular evidence attributing a blow to the accused is corroborated by medical evidence showing a fatal head injury caused by a hard and blunt object.
(Paras 3.7–3.9, 5.3–5.4)

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Right of private defence – Extent

Where the accused also suffers injuries in the same occurrence and the incident arises out of a sudden clash, the plea of private defence may explain absence of premeditation, but does not exonerate the accused when his individual act causes death with knowledge of likely consequences.
(Paras 3.3, 5.3–5.5)

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Sentencing – Reduction on humanitarian grounds

Advanced age – Long lapse of time – Period already undergone

While upholding conviction under Section 304 Part II IPC, the sentence may be reduced to period already undergone, considering advanced age of the appellant, long passage of time since the offence, and substantial incarceration already suffered.
(Paras 6–6.1)

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ANALYSIS

1. Nature of the incident

The occurrence arose from a sudden quarrel between neighbours, culminating in a free fight involving both sides. Injuries were suffered by the deceased as well as by the appellant.
(Paras 3–3.4, 5.2)

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2. Absence of common object

The Court affirmed the High Court’s finding that the facts did not disclose formation of an unlawful assembly with a common object to kill. Consequently, collective liability under Section 149 IPC was ruled out.
(Paras 5.2–5.2.1)

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3. Individual role of the appellant

The appellant’s liability was assessed individually, based on evidence that he delivered a lathi blow on the head of the deceased. The medical evidence confirmed a fatal head injury caused by a blunt object.
(Paras 3.7–3.9, 5.3–5.4)

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4. Distinction between murder and culpable homicide

The Court revisited the statutory distinction between Sections 299, 300, and 304 IPC, reiterating that absence of intention to cause death, coupled with presence of knowledge of likely fatal consequences, attracts Section 304 Part II IPC.
(Paras 5.1–5.1.5)

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5. Application to facts

Given the suddenness of the fight, lack of premeditation, use of a blunt weapon, and the context of mutual assault, the offence did not amount to murder. However, the appellant was attributed knowledge that the act could cause death.
(Paras 5.4–5.6)

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6. Sentence modification

Although conviction was sustained, the Court exercised discretion to reduce the sentence to period already undergone, considering that the appellant was over 80 years of age and had already undergone more than six years of incarceration.
(Paras 6–6.1)

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RATIO DECIDENDI

1. A single fatal blow inflicted with a blunt weapon during a sudden quarrel, without premeditation, attracts Section 304 Part II IPC when the accused acts with knowledge of likely death but without intention to kill.

2. In a free fight with injuries on both sides, absence of prior concert or meeting of minds negates common object under Section 149 IPC.

3. Medical evidence corroborating ocular testimony regarding a fatal head injury is sufficient to sustain conviction under Section 304 Part II IPC.

4. Advanced age of the accused, long lapse of time since the offence, and substantial incarceration already undergone justify reduction of sentence to the period already served, without disturbing the conviction.

Jurisdiction under Section 439 CrPC is limited to deciding bail and does not empower the High Court to issue mandatory or general directions governing investigation or evidence collection. The High Court cannot enlarge statutory bail jurisdiction by invoking its constitutional status; constitutional and statutory powers operate in distinct spheres. Medical age determination of a POCSO victim cannot be mandated as a matter of course and may be resorted to only in the absence of documentary evidence contemplated under Section 94 of the JJ Act. Determination of the victim’s age is a matter for trial; at the bail stage, courts may take only a prima facie view without testing the correctness of age-related documents. A bail court cannot conduct a mini trial, re-appreciate evidence, or order investigative exercises such as constitution of medical boards for age determination. Judicial directions cannot override or dilute the legislative scheme under Section 94 JJ Act by compelling medical age determination in every POCSO case.

Criminal Procedure Code, 1973 – Section 439

Scope of bail jurisdiction – Limits – Issuance of general directions

Jurisdiction under Section 439 CrPC is confined to deciding whether the accused should be released on bail pending trial. The High Court, while exercising bail jurisdiction, cannot issue general or mandatory directions governing investigation, nor can it enlarge the scope of statutory powers by invoking its constitutional status.
(Paras 10–11.5, 18)

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High Court – Constitutional powers vs. statutory jurisdiction

Fusion impermissible

Although the High Court is a constitutional court, constitutional status cannot be used to expand a narrowly circumscribed statutory jurisdiction. Powers exercised under Section 439 CrPC remain statutory and cannot be enlarged by reference to constitutional obligations.
(Paras 11.2–11.5, 18)

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POCSO Act, 2012 – Section 27 r/w Section 164-A CrPC

Medical examination – Scope

Medical examination under Section 27 POCSO Act read with Section 164-A CrPC is meant for collection of medical evidence relating to sexual assault. These provisions do not mandate compulsory medical age determination of the victim in every POCSO case.
(Paras 8.1–8.2, 12, 17–18)

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Juvenile Justice (Care and Protection of Children) Act, 2015 – Section 94

Age determination – Hierarchy of evidence

Section 94 prescribes a statutory hierarchy for age determination:
(i) school/matriculation certificate,
(ii) municipal birth certificate, and
(iii) medical opinion only in absence of (i) and (ii).
Medical age determination cannot be mandated as a matter of course and can be resorted to only when statutory documents are unavailable.
(Paras 8.3, 13.1, 16–17)

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Victim under POCSO Act – Determination of age

Stage and forum

Determination of the age of the victim under POCSO Act is a matter for trial, not for adjudication at the stage of bail. At the bail stage, the Court may take only a prima facie view based on documents, without examining their correctness.
(Paras 14.8–14.10, 16, 18)

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Bail proceedings – Mini trial

Impermissibility

A bail court cannot conduct a mini trial, re-appreciate evidence, test the correctness of age-related documents, or direct investigative exercises such as constitution of medical boards for age determination.
(Paras 15–15.3, 16, 18)

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POCSO Act – Presumption and legislative intent

Strict adherence to statutory scheme

Judicial directions cannot override or dilute the legislative intent underlying Section 94 JJ Act by mandating medical age determination in every case. Courts must adhere to the procedure expressly provided by Parliament.
(Paras 17–18)

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Effect on prior High Court judgments

Prospective operation

Directions issued in Aman v. State of U.P. and Monish v. State of U.P., being intrinsically connected to the impugned judgment, stand set aside. However, the effect of the present judgment is prospective, and bail already granted under those judgments is not disturbed.
(Para 20(b)–(d))

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ANALYSIS

1. Core issue

The Supreme Court examined whether the High Court, while exercising bail jurisdiction under Section 439 CrPC, could (i) mandate medical age determination of victims in all POCSO cases, and (ii) adjudicate the correctness of age-related documents at the bail stage.
(Paras 6–7, 10)

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2. Jurisdictional transgression

The Court held that the High Court overstepped its jurisdiction by issuing general directions affecting investigation. Bail jurisdiction is limited and cannot be converted into a supervisory or law-making exercise.
(Paras 11–11.5)

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3. Constitutional vs. statutory power

A detailed distinction was drawn between constitutional powers and statutory powers, emphasizing that constitutional status does not permit expansion of statutory jurisdiction.
(Paras 11.3–11.5)

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4. Statutory scheme of age determination

The Court reaffirmed that Section 94 JJ Act governs age determination even for POCSO victims, following Jarnail Singh v. State of Haryana, and that medical tests are the last resort, not the first.
(Paras 13.1, 14.6–14.7, 16–17)

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5. Bail stage limitations

At the bail stage, courts may only examine whether age documents exist and what they disclose prima facie. Any challenge to their authenticity or correctness must await trial, as testing them would amount to a mini trial.
(Paras 14.10, 15–16)

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6. Victim vs. juvenile offender

The Court carefully distinguished between juvenility claims by accused persons, which may be raised at any stage, and age determination of victims, which must be settled early and conclusively at trial to avoid vitiation of proceedings.
(Paras 14.9–14.10)

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7. Caution on misuse of POCSO

While disapproving the High Court’s directions, the Court acknowledged concerns regarding misuse of POCSO Act in consensual adolescent relationships and suggested legislative consideration, including a possible Romeo-Juliet clause.
(Paras 19–20)

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RATIO DECIDENDI

1. Jurisdiction under Section 439 CrPC is limited to deciding bail and does not empower the High Court to issue mandatory or general directions governing investigation or evidence collection.

2. The High Court cannot enlarge statutory bail jurisdiction by invoking its constitutional status; constitutional and statutory powers operate in distinct spheres.

3. Medical age determination of a POCSO victim cannot be mandated as a matter of course and may be resorted to only in the absence of documentary evidence contemplated under Section 94 of the JJ Act.

4. Determination of the victim’s age is a matter for trial; at the bail stage, courts may take only a prima facie view without testing the correctness of age-related documents.

5. A bail court cannot conduct a mini trial, re-appreciate evidence, or order investigative exercises such as constitution of medical boards for age determination.

6. Judicial directions cannot override or dilute the legislative scheme under Section 94 JJ Act by compelling medical age determination in every POCSO case.