Supreme Court has held that the offence of murder punishable under Section 302 of the Indian Penal Code (now Section 103(1) of the Bharatiya Nyaya Sanhita) is a "heinous offence" under the Juvenile Justice (Care and Protection of Children) Act, 2015, ruling that imprisonment for life constitutes its implied minimum punishment even though the provision does not expressly prescribe a minimum sentence.

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https://www.livelaw.in/supreme-court/supreme-court-heinous-offence-juvenile-justice-act-2015-preliminary-assessment-542300