The world is observing an increase in the crimes done by juveniles, it is a serious issue as the juveniles are the future of their respective countries. Children who doesn't receive any proper guidance, may attracts towards the criminal activities to lead their lives.

The term "juvenile justice" in a comprehensive sense, includes the legal regulations, and is used to classify sociologically, educationally or psychologically definable perspective from a juvenile point of view. The juvenile justice system of different countries depends on the social and political condition of that country.

However, the comparison of legal systems particularly in juvenile justice system of two countries is quite challenging. By examining the two justice systems, will allow us to identify the common problems faced by both Juvenile justice systems, and we can get to know the strengths and weaknesses of a particular Juvenile justice system.

This research article shall focus on the comparison of juvenile justice system of Germany and India in its historical and cultural context. This article shall also focus on why Germany has high rate of juvenile delinquency than India, how the legislation of both countries deals with juvenile delinquency and how family and community has an impact on juvenile delinquency.

Introduction
The terms "Juveniles," "Juvenile Delinquency," and "Child in need of care and protection" holds significant importance in addressing young offenders and child in vulnerability. Germany's juvenile justice system, which is totally based on the European Union justice system, gives more emphasis to education in place of punishing younger offenders, with a purpose to help them in becoming responsible adults. specialized youth chambers are established in courts under the "Jugendstrafrecht" legal framework, which operates with a completely unique emphasis on helping offenders among the ages of 14 and 20.

Judges, social workers, and psychologists work together in these chambers to decide which approach would be appropriate for juvenile offenders. Germany's approach gives preference to social welfare and education over incarceration and favours alternative measures like counseling, and probation.

On the other hand, under the Juvenile Justice (Care and Protection of Children) Act of 2015, India's juvenile justice system gives a high priority to the welfare and rehabilitation of those under the age of 18. Juvenile Justice Board (JJBs) have set up a system that aims to offer young offenders a second chance by prioritizing their overall welfare and reintegration in society.

India encourages the alternative approaches, but it also aims to protect juvenile offender's rights by upholding their confidentiality and allowing report sealing or its erasure. Because these two juvenile justice systems come from very different cultural backgrounds, comparing them will teach us a lot about social control techniques and how they respond to improper and deviant behavior.

Historical Background Of Juvenile Justice Systems:

Germany's juvenile justice system began to take shape in the late 19th and early 20th centuries. The particular legislation was only successful after World War II, but in the early 1900s, specifically in 1908, a special court was established. The Jugendwohlfahrtsgesetz, or Juvenile Welfare Act, was passed in 1922 and it dealt with children and young people in need of care.

One year later, in 1923, the Juvenile Justice Act was enacted, which was designed expressly for juvenile offenders who had previously committed crimes as defined by general criminal law. The Juvenile Justice Act outlines particular responses and penalties for young offenders in addition to some procedural guidelines for the juvenile courts and related processes.

Three pillars for innovation have been established by the 1923 legislation. First, the 1923 legislation opened the door for educational measures rather than punishment, which is against the general penal law. Second, it became possible to waive the rigorously enforced principle of mandatory prosecution. Finally, the age of criminal liability was increased from 12 to 14 years old. The Juvenile Justice Act of 1943 underwent some changes in the Nazi era.

But the legislature raised the age of criminal responsibility from 12 to 14 years old again after World War II. "Disciplinary measures" were kept in place by the 1953 reforms because other European nations also used the same strategy. The inclusion of young adults between the ages of 18 and 21 in the juvenile court's jurisdiction was one of the major amendments of 1953, which will soon decide whether to apply the JJ Act or the general penal law.

The 1922 act provided the provision relating to "Parens Patriae," according to which the state shall replace the parents who were unable or unwilling to fulfill their duties towards their child's education. But in 1990, the Juvenile Welfare Act gave way to a more recent social welfare system known as Sozialstaat, or the social welfare state. The German Juvenile Justice Act was subsequently amended to improve its efficacy in reforming juvenile offenders.

However, the history of this act shows that Germany is taking a moderate stance toward its young offenders, offering a facility for reformation and only imposing punitive sanctions in the most extreme and violent of circumstances. In recent Germany has two laws dealing with the juveniles i.e. Youth Courts Act (YCA) which address juvenile and young offenders and Child and Youth Services Act (CYSA) which address child in need of care and protection.

In order to serve the needs and uphold the rights of young offenders, the juvenile justice system in India has evolved over time. Before self-government in the early years under British rule, the concept of a separate juvenile justice system first emerged. As opposed to subjecting youth offenders to adult criminal justice system, the apprenticeship system was widely used in this system the juveniles were kept under the supervision of a master to train them in a trade.

The Madras Children Act of 1920 became one of the first laws in British India to deal with the needs of young offenders. Juvenile justice issues continued in India even after we got independence in 1947.

The Children's Act of 1960 ensured the rights to care, treatment, and safety for children who are neglected or involved in criminal activity. The need for a more thorough and child focused approach has emerged through the years. The 1986, Juvenile Justice Act is a significant piece of legislation, that has significantly changed how juvenile offenders were treated.

It gives more emphasis on juvenile offender's rehabilitation and reintegration into society rather than giving them punishment. The Act created juvenile courts and juvenile justice boards to address instances related to younger offenders. The Juvenile Justice (Care and protection of Children) Act, 2000 took the place of the 1986 Act. This act has given more importance to child's needs, with a focus on social reintegration and rehabilitation of the children in to the society.

The Juvenile Justice Board (JJB) and the Child Welfare Committee (CWC) have been proposed as methods to cope with problems concerning young offenders. The Juvenile Justice (Care and Protection of Children) Act, 2015, replaced the 2000 Act following substantial adjustments. The new Act's important goal was to make aspects of social reintegration and rehabilitation even stronger.

It implemented provisions addressing a number of issues, including the age of criminal responsibility and the procedures for dealing with serious crimes committed by minors. The Juvenile Justice (Care and Protection of Children) Act, 2015 has recently undergone additional modifications to address new concerns and issues.

Scope of Juvenile Justice Laws

In India, the Juvenile Justice care and Protection Act, 2015 is in prevalence, which was enacted on 31st December, 2015 and came into force on 15th January, 2016 by replacing the earlier act of 2000, one of the reason for the amendment of the act was Delhi gang rape case which urged the necessity of the amendment of the Juvenile justice act because one of the offender of this case was only 17 years old.

There was no clear distinction between the child in need of care and protection and child in conflict with the law in the earlier act, also the act didn't had any provision for the reporting of lost and abandoned children to the appropriate authority. In 2015 act, the nomenclature of "juvenile" was changed to "child" and "child in conflict with law", also the act provides provision for the adoption of surrendered, orphaned, and abandoned child.

As per the previous act, any minor could only receive a maximum sentence of three years in prison, regardless of the crime they committed. The minor could not, under any circumstances, be convicted for more than three years, or tried in an adult court, or sent to adult jail.

However, 2015 amendment act, has brought some changes in this condition. All children would receive equal treatment who are under the age of 18 years, but an exception to this rule is that if any child between the age group of 16 - 18 years is accused of committing any heinous crime, then in such a case, the child shall be treated as an adult and shall be tried like an adult.

The issue relating to minimum age culpability is dealt with as per sections 82 and 83 of Indian Penal Code (IPC). A complete immunity is given to the child below the age of 7 years if anything is done by such child, and the immunity is subjective for a child between the age group of 7 to 12 years of age depending on the maturity level to understand the nature and the consequence of his act on that particular occasion.

Thus, according to section 83 of IPC, the JJ act is applicable to the children between the age group of 7 - 18 years. A juvenile cannot only apprehended under the principal criminal law but can also be apprehended under Special and Local laws.

In India, the issues relating to Child in need of care and protection and Child in conflict with law is dealt by one act only i.e. by Juvenile Justice act, 2015, while in Germany these two issues are dealt by two different laws i.e. Child and Youth Services Act (CYSA) and Youth Courts Act (YCA). This split was introduced in 1923 and it is still there. One of the main reason for this split may be, both the two issues is dealt by two different institutions.

The CYSA deals with youth welfare institutions, which are special branches of social services, while the YCA addresses juvenile justice institutions, which are special branches of criminal justice institutions. Since 1923, the age of criminal responsibility in Germany is 14 years. Juveniles among the age group of 14 - 18 years are liable for the punishment, if they have reached such a level of maturity to understand the consequences of the wrongful act. Juveniles who commit the same acts as adults can be punished; in Germany, unlike in some other Western states, there are no status offenses that apply only to minors, such as the ban on alcohol consumption, smoking or running away from home.

Theft (shoplifting), property damage, and fraud, are the most common crimes committed by young people in Germany between the ages of 14 and 17. Youth welfare institutions take up the case if the court determines that the juvenile doesn't fulfill the requirements for punishment or that the child, who is under 14 years old, commits an act that is punishable by law.

If necessary, the family court may then determine what steps can be taken. In 1953, adolescents between the age group of 18 to 21 years of age were included in juvenile justice system. The debate on the inclusion of adolescents in the juvenile justice system is still going on, it is because the persons who are accountable to civil law, who are allowed to vote, marry, fight in war, are differently treated by criminal law.

However, the YCA's extension has been preserved for more than 50 years at this point, regardless of the political parties in power in Berlin or Bonn. One of the reasons that the inclusion has still remained is that the young adults are not treated exactly similarly like juveniles. In comparison to the juvenile offenders, the young adults of course have reached the maturity level which is an essential requirement for the punishment of adults.

It is the court that has to decide, whether to punish young adults as per the principle of YCA or as per the principles of general criminal law for the adults. The purpose for the application of this concept is that, adolescent who still behaves like juveniles, their future behaviour can be appropriately influenced by the application of juvenile category on them.

Juvenile Delinquency:

Juvenile delinquency, commonly referred to as juvenile offending, is the act of engaging in illegal activity by a minor or someone under the legal majority age. In addition, the term delinquent is generally used to describe juvenile delinquency, and it can also be used to describe any young person who shows unacceptable behaviour. Situational factors and family environments, such as parenting style, peer group association, peer rejection, and the child's immediate social environment, are among the factors that influence juvenile delinquency.

One of the reasons for juvenile delinquency is stricter or neglectful parenting; the juvenile offender may see delinquent behavior as a means to obtain resources to protect against the threat of violence or financial hardship.

Facts:
If we are comparing the crime and delinquency rates of two different nations, police statistics are essential. If someone reports an illegal act, usually the victim or a member of their family, the police will file a complaint report. The victim's decision to report such crimes depends on a variety of social and personal factors.

For example, the victim may believe that there are other ways to restore peace and order after the crime has occurred rather than reporting crimes of such a minor nature. All of these factors may differ between the two countries due to the differences in the socio-legal traditions of police connections. Consequently, the same factor is possible for the offender. The offender may respond differently to being taken into custody by the police or the victim, and one extremely effective tactic could be bribery.

Effect Of Society On Juvenile Delinquency In India And Germany

Several informal social norms have a strong cultural influence on the upbringing of young people in India. A wide range of principles derived from religion, social institutions, customs, culture, and strong observance of these practices govern Indian society. This integrated system of social norms has drawn a line between what is desirable and undesirable in human behavior in order to uphold fundamental values.

Social sanctions are used to guarantee that these operating norms within the society are followed. For e.g. in India a person who belongs to upper caste cannot marry an individual of lower class, if he does then, his/ her entire family is expelled from the caste. A major factor in the transition of young people from institutionalized family life to social life is the manner in which religious instruction and moral values are taught to them through the family unit. Furthermore, a central force that ties behavior around social desirability is social taboos, which are strong social prohibitions against certain behaviors or omissions.

Having relationships with girls or boys before marriage, getting married outside of one's caste, and smoking or drinking in public are still taboo for young people in India. In certain cases, breaking these taboos would result in harsh consequences from society or family. These are some social parameters because of which the rate of juvenile delinquency in India is less than Germany.

Minors in Germany, in contrast to those in India, are raised in a culture that values diversity in values and lifestyles. It is possible to identify the individualization and anonymization of social relationships as key characteristics of German society. According to Ulrich Beck, in a society where individuals are valued for who they are, identity is no longer "given" but rather viewed as a "task," entrusting performers with the responsibility of acting and bearing the consequences of their actions, the determination of social standing is supplanted by an obsessive and required process of self-determination.

The Indian and German conceptions of family are different in a society, as Germany follows the concept of individualism. Despite the fact that the family unit serves the same purposes ensuring procreation, fostering socialization, and fostering economic cooperation the variety of homes and living situations is significantly greater. In German society, families with just one child and single parents are not uncommon: In 2022, over half of the families (53%) had only one child, and nearly one-quarter (20%) of all families consisted of a single parent.

Although marriage is still a concept, but it is not meant to last a lifetime; the figures for marriage ages indicate that second and even third marriages occur. In Germany, men marry at the average age of 37 and women at the average age of 33.

Divorce rates are relatively high, despite a recent decline in these numbers. In 2022, around 35% of divorced couples reported having at least one minor child in the home. As a result, a large number of kids grow up in what is known as a "patchwork family," a situation where informal relationships take the place of formal ones. In Germany religion plays very minor in everyday life.

However, the Germany defines itself as a Christian country, the bible is the holy book which is considered as equivalent to the Manusmriti, however it doesn't act as guidelines or set of rules for many people, not even for those who are the member of catholic or protestant church. In Germany people are not usual to the religion, they have only narrow and limited knowledge of their religion and holy scriptures. Most people have by hearted learned the 10 commandments, and some people are applying only those principle of Christianity that fits in their every day life and by ignoring the other principles.

Thus, the process of individualization has affected most aspects of social life, which is the reason for Germany's high juvenile delinquency rate. A weakening of social ties could have shifted authority of responsibility from informal social institutions to formal juvenile justice institutions, such as the police, etc.

Reaction To Juvenile Delinquency:

In India, the principle criminal law is IPC, under Sec - 53 of the act, various kinds of punishment are prescribed such as death penalty, life imprisonment, forfeiture of property, fine, simple or rigorous Imprisonment, etc. for adults. On the other hand the Juvenile justice act, provides very limited punishment for the juveniles.

Under sec - 16 of the act it is clearly mentioned that no juvenile shall be sentenced to life imprisonment or death penalty. If the Board is satisfied that, an offence is committed by the juvenile, then the board can pass an order subject to sec - 15. These orders are in the form of corrective measures with the aim to reintegrate the juvenile in to the society again.

The orders are generally in the form to perform community service or fine. The trend in India seems to be focused on non - institutional corrective measures than the formal institution. As per the JJ act, the juvenile can be sent to correctional home for a maximum period of 3 years only, located nearest to the place of residence of parents.

But in case of most heinous crimes committed by the minors between 16 - 18 years, they can be tried as an adult. The order includes the "individual care plan" for particular juvenile. The individual care plan is executed to meet each and every need of the concerned juvenile, such as mental - physical, training and education, post release curriculum and restoration, relationship and attachments, etc. the restoration of juvenile's self -esteem, self worth and to make them responsible citizen is ensured.

The facilities of transitional homes are also created, these facilities are for the 18 - 21 years old, such facilities enable the children to become adapt to the society after moving away form institution life to normal life. This facilities are mainly for those who are unable to support themselves after moving out from the institution.

The entire process focuses on reformation of the juvenile and its reintegration in to the society, by reducing all the possibilities of victimization. To over come the stigmatization all the records relating to the juvenile offence is destroyed and the identity of juvenile is not disclosed publicly. Thus, the criminal administration in India pertaining to juvenile is redefined for its welfare.

The situation in Germany is different. In Germany, the juvenile delinquency is treated in a way of criminal justice by the criminal justice institutions. The legal procedure and consequences are oriented towards the concept of Youth Courts Act, which aims to prevent further offences. If court convicts a juvenile formally, then it may choose from the different punishment that can be imposed on juvenile. In severe offences, the decision is depended on the severity of the offence, and in all other cases, the YCA educational concept is to be considered.

The form of punishment in Germany to send youth in the youth prison for the execution of sentence distinguishes it form the Indian system, the correctional homes or special homes are made which are intentionally not regarded as jail, but they are regarded as reformatory institutions, but in Germany the youth are sent to the high security jails for the execution of sentence for a duration of 6 months or up to 5 years and in the severe cases it may extend up to 10 years. The Germany's aim to execute such sentences is two folded i.e.

On the one hand, it's a response to how serious the youth's guilt is, and on the other hand it is seen as measure of reintegration and rehabilitation of youth. The great majority of sanctions imposed on juvenile offenders in Germany are non-custodial measures, ranging from probation over disciplinary measures to supervisory measures, apart from the detention of youth for up to four weeks and supervised accommodation.

Some examples include orders to carry out specific actions, to repair the harm that the offense caused, to give a small sum of money to a charitable trust, or to enroll in a social skills training program. Thus, the range of non-custodial sanctions that apply is as distinct in German law as it is in Indian law.

Organization Of The Juvenile Justice System:

In India, in most of cases, the first contact of juveniles is with the police, it seems to be ruthless because the police officers have a traditional mindset and training to deal with adult criminals. Thus keeping in mind the situation of both the helpless juvenile and non-specialised administration, a "Special Juvenile Police Unit" (SJPU) was established to overcome the loophole.

As per the JJ act, The SJPU is to be established in every district of the state and shall consists of Juvenile or Child Welfare officer (JCWO) equivalent to the rank of Police Inspector and other two members shall be paid social workers and among these 2 members one shall be a woman. The SP of the district shall act as the head of SJPU and observe the functioning of it.

The JJ Act and rules has prescribed the code of conduct while dealing with the juvenile offenders. A juvenile can be apprehended in cases for an offense punishable with imprisonment for more than 7 years. If the offense is punishable with imprisonment of less than 7 years, then apprehension is permitted only in the general interest of the juvenile. And in petty cases, the police officer shall dispose off the case in the police station itself.

The police shall not handcuff the juvenile or send the offender to lock up or jail. The police shall within 24 hours of apprehension of juvenile offender produce the offender before the board, if the board is not sitting then before a single member of the board. The police officer is authorized to attend the board proceeding but in civil dress only not in police uniform. The second important authority to maintain the purity of JJ system is Juvenile Justice Board which was established in 2006 as per the JJ Amendment Act 2006.

The board consists of a Metropolitan or Judicial Magistrate and 2 social workers of whom at least one shall be a woman. The magistrate must have knowledge or training in child psychology or child welfare and social worker must have been actively involved in education, health or welfare activities relating to children for at least seven years.

The board has the authority to deal with the cases relating to juveniles in conflict with law. The JJ(C&P)A has been successful in maintaining juvenile's mental and physical integrity. By holding proceedings in the Observation Home, where the juvenile may be detained, rather than on the court premises, the psychological impact on delicate minds is reduced.

In Germany unlinke India, the courts and public prosecutors works as the essential components in the juvenile justice and not the police and JJ boards are the key players. The German Juvenile Justice system is justice oriented system which is different from welfare oriented philosophy which is followed by India and this is the reason for the divergence in both the countries.

In Germany the juvenile justice is viewed as a significant branch of Criminal justice system only and thus the general guidelines for the criminal procedure against the adult is followed in juvenile cases by keeping trial in its centre and the court as its main actor. This is because Germany follows the inquisitorial system and not the adversarial system, which is followed by other European countries, in this system the trial is governed by the court, especially by the presiding judge, and not by a public prosecutor and the defence counsel.

In Germany, the police only acts as an auxiliary force by law for the prosecution. Legally, the public prosecutor's decision and order determines the police's authority, From the legal point of view, the authority of the police is dependent upon the orders and decisions of the public prosecutor, but in actual practice, the police operate independently and have the ability to shape the case and its resolution through the accuracy and depth of their criminal investigations.

The judges and the Public prosecutors are not social workers, but they are jurists by their formal education. These people are qualified in law and it is expected that they have an additional education, experience and training in upbringing of youth, however, such additional competence is not being indispensable (sec. 37 YCA).

The lack of professional experience and expertise in handling and understanding the youth is fulfilled by the involvement of the youth welfare institutions in the juvenile proceedings. A specialized youth court assistance service must be offered by the youth welfare offices, and it must be involved in all phases of the proceedings. Its job is to draw attention to the aspects of supervision, social work, and caregiving that are involved in the proceedings, whether they take place during an investigation, a trial, or the execution of non-custodial sentences.

The services of the youth court assistance are viewed as a connecting line between the social welfare services and criminal justice institutions from the organizational point of view (sec. 38 YCA, sec. 52 CYSA). Despite of the fact that, legal position of the police is determined by their reliance on the public prosecutor's directives, the factual situation of the police should not be undervalued.

Therefore, the German police ensures to maintain high standard of education and ongoing training of the officers who are tasked with the handling of the Juvenile justice cases. The administrative rules governing all the police actions clearly state that juvenile justice is different from the general principles of criminal justice, and thus it focuses on the future behaviour of the juveniles and the avoidance of further offences.

This particular distribution of aggravating factors that is present in Germany appears to be similar to the circumstances in India, where a significant portion of the youth involved in criminal activity are from low-income families, are illiterate, or have only completed primary school. Delinquency and crime appear to be related to social and economic standing in both nations.

Comparative Analysis:
There are numerous similarities between the juvenile justice systems in Germany and India. Juvenile delinquency is viewed as a social issue in both nations that needs to be addressed by society. Social control agencies become involved when young people break the law and disrupt society as a whole.

Parents and other informal and formal control stakeholders, as well as legal institutions like the police, courts, and prisons, have a greater stake in the next generation to make them law abiding citizens. The language used in the German Youth Courts Act ("The legal consequences and the process regarding the parental right to raise a child should be oriented predominantly in line with the educational concept") is strikingly similar to that of the Indian Juvenile Justice Act 2015 ("a child-friendly procedure for deciding cases in the best interests of children and ensuring their eventual rehabilitation"). However, it is evident that there is always an inconsistency between the written and unwritten laws which may be particularly true for India.

The legal frameworks of both nations meet the standards and requirements of international conventions and recommendations, including the UN Convention on the Rights of the Child, the UN Guidelines for the Prevention of Juvenile Delinquency (Riyadh Guidelines), and the UN Standard Minimum Rules for the Administration of Juvenile Justice (Beijing Rules).

India and Germany adopt different strategies in an effort to shape the behavior of young offenders and increase their capacity to help them to become law-abiding citizen. Various models are discussed in the international scholarly debate and can be distinguished when analyzing juvenile justice systems.

Using these typologies and ignoring specifics, it is possible to conclude that Germany adopts a justice-oriented approach and India adopts a welfare-oriented one. The differences are readily apparent when contrasting the primary sanction categories (youth penalty vs. Special homes) and organizational structures (youth court vs. juvenile justice board).

Additionally, different legal interpretations provide supporting evidence (addressing both children in need of care and protection and child in conflict with law in a single act vs. dividing the issues into two acts, the Youth Courts Act and the Child and Youth Services Act). However, labelling programs as welfare or justice approaches oversimplifies the complicated structure of juvenile justice.

There are components in both systems that, in theory, are part of the corresponding counter-model; for example, in Germany youth court assistance service is involved, and in India, there is accentuation of the provision of legal aid system. Though the legal foundations differ, both systems exhibit a notable resemblance in their essentially altruistic outlook on juvenile offenders.. In general, both juvenile justice systems are similar to certain extent.

We propose that the primary reason for this unanticipated discovery could be the distinct cultural environments in which young people grow up in both nations, which are distinguished by varying levels of informal social control In India, family, community, and religion appear to have a more stabilizing effect on youth socialization than they do in Germany.

Future developments in India could lead to a decline in the power of informal control agencies and the emergence of new value systems as modernization continues. However, as of right now, Indian social traditions continue to appear to have a positive influence on young people's daily lives. The more influential the informal control agencies are, the less seems to be required for the formal juvenile justice system to regulate the behaviour of the youth.

Despite their emphasis on education and the development of juveniles, the German juvenile justice system is not without flaws. For example, there is a higher rate of juvenile delinquency, and another issue is their lenient attitude toward serious juvenile offenses. Some of the shortcomings of the juvenile justice system in India include possible gaps in the educational opportunities provided in the juvenile homes, social stigma, and a lack of infrastructure for the rehabilitation of the juvenile offender.

Conclusion
In conclusion, the comparative analysis of Juvenile system of India and Germany provides that, there is a need for a cooperative and comprehensive approach to deal with the problems relating to juvenile delinquency. The Germany's approach character development and education has proven to be successful in many facets, but it is still facing problems such as high juvenile delinquency rate and its lenient approach towards serious offences.

On the other hand India's approach of welfare and rehabilitation of the children in the society, also facing problem such as societal stigma and limited educational opportunities. A collective approach that combines the strengths of both the systems i.e.

Germany's educational approach and India's holistic approach shall be made. It shall help in the creation of more efficient and balanced juvenile justice system. Public awareness, continuous evaluation and allocation of resources is essential for enhancing the resilience of these systems and the successful reintegration of juvenile offenders in the society.

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