Revisiting India’s Rehabilitative Approach to Juvenile Justice: Reflections One Year After the Pune Porsche Case

I. Introduction

The widespread outrage sparked by the 2024 judgement in the ‘Pune Porsche Accident’ raised grim questions about the Juvenile Justice (Care and Protection of Children) Act’s role in shielding juveniles from accountability, potentially emboldening them to commit offences with impunity. Although the latest National Crime Records Bureau (NCRB) report of 2022 offers contrasting evidence—as the cases lodged against juveniles have decreased by approximately 2% from 2021—17 states witnessed a surge in juvenile cases (with the majority of offenders belonging to the age group of 16-18) causing the overall data to remain a concerning figure.² In light of such trends, revisiting the JJ Act and examining its efficiency is essential.

Therefore, through the lens of the 2024 case, this paper aims to critically analyse the rehabilitative approach of the JJ Act of 2015, which in its current application, especially in cases of gross negligence and misuse of social status, may lead to an apparent miscarriage of justice. This paper explores the reasoning behind the emphasis on rehabilitative measures in the Indian juvenile justice system, discusses Sections 15 and 18 of the JJ Act, and compares the judgement with the verdict delivered in international cases involving similar elements. Finally, the paper concludes with various recommendations, backed by reason, that can be integrated into the juvenile justice system to tackle delinquents and effectively reform them into responsible citizens, while safeguarding the principles of justice, accountability, and the rule of law.

II. Juvenile justice (care and protection of children) act, 2015

The Juvenile Justice (Care and Protection of Children) Act of 2015, which replaced the Juvenile Justice Act of 2000, was introduced to tackle crimes or unlawful acts committed by juveniles. It seeks to effectively address concerns regarding the treatment of juveniles involved in heinous crimes, followed by nationwide outcries for the same caused by the brutal Nirbhaya Rape Case.³ Prior to this, punitive measures did not apply to juveniles involved in heinous crimes.

Therefore, the JJ Act of 2015 serves as a notable piece of legislation that plays a crucial role in determining the consequences of juvenile delinquency, or the violation of law by an individual aged between 7 and 18. While it emphasises providing children in conflict with the law with rehabilitation opportunities, it also entails appropriate measures in response to heinous offences committed by juveniles between the ages of 16 and 18. These are discussed in Section 18 and Section 15 of the Act respectively, and the distinction between them is key to evaluating how cases like the Pune Porsche incident are handled under the law. Understanding the meaning of the following terminologies will further help clarify this distinction:

1. Petty Offences: “Includes the offences for which the maximum punishment under the Indian Penal Code (45 of 1860) or any other law for the time being in force is imprisonment up to three years.”⁴

2. Serious Offences: “Includes the offences for which the punishment under the Indian Penal Code (45 of 1860) or any other law for the time being in force, is imprisonment between three to seven years.”⁵

3. Heinous Offences: “Includes the offences for which the minimum punishment under the Indian Penal Code (45 of 1860) or any other law for the time being in force is imprisonment for seven years or more.”⁶

III. Section 15 of the jj act, 2015

Section 15 mandates a preliminary assessment—in which the Juvenile Justice Board can seek assistance from experienced psychologists and other experts—for juveniles aged 16-18 accused of heinous offences, aiming to examine the indicating mental and physical capacity to commit the offence, their understanding of its consequences, and the circumstances of the alleged act.⁷ If the Board is satisfied with the outcome, indicating adequate maturity held by the juvenile, then it may pass an order under Section 18(3) to transfer the trial of the case to the Children’s Court having jurisdiction to try such offences.⁸ Otherwise, it may itself dispose of the matter, following the procedure for trial of summons cases.⁹

IV. Section 18 of the jj act, 2015

Unlike Section 15 which focuses on examining the mental capacity of the juvenile (aged 16 to 18) to commit the heinous offence, Section 18 deals with the suitable rehabilitative measures that can be recommended. Thus, in case a child is found to be in conflict with the law, upon having committed a petty offence or a serious offence, or a child below the age of 16 years is found to have committed a heinous offence, and the Board deems it fit, upon investigation, it can impose several rehabilitative measures– including allowing the child to go home after advice or admonition following appropriate inquiry and counselling, directing the child to participate in group counselling and similar activities, ordering the child to perform community service under the supervision of an organisation, institution, or a specified person, persons or group of persons identified by the Board, and other such similar rehabilitative actions.¹⁰

V. Rehabilitative vs punitive measures

A common question in juvenile delinquency cases is whether the law is lenient towards juveniles. Unlike laws governing adults, the JJ Act of 2015 emphasises on rehabilitation rather than punitive measures, stemming from the notion that juveniles are largely shaped by their circumstances and that they can be easily reformed as they are in their developmental phase and not fully mature.

The findings of a psychological report support this theory by explaining that the prefrontal cortex, pivotal for decision-making and impulse control, is not fully developed in adolescents, and can be influenced by active intervention, making juveniles more amenable to change as compared to adults. Thus, rehabilitative actions are widely viewed as a more suitable approach to reform juveniles into responsible individuals and prevent them from re-offending.¹¹ Reports suggest that rehabilitation efforts—aimed at addressing the underlying cause of the crime—not only yield long-lasting results, but also decrease the recidivism rate more effectively than punitive measures.¹²

However, according to another study, the outcome yielded by the rehabilitative approach largely depends on factors like quality and implementation. Thus, in cases involving substance abuse by a juvenile, if the rehabilitative effort fails to address the underlying issue of addiction effectively, it would be likely for them to re-offend, making their reintegration prospects into society unfavourable. Additionally, investing in providing positive experiences within juvenile institutions and tailoring the services to suit the juvenile can reinforce their urge to reform and reduce recidivism rates.¹³

Therefore, while it is perhaps universally acknowledged that a rehabilitative approach is better than imposing punitive measures, its effectiveness heavily relies on proper implementation, tailored to suit the individual needs of juveniles, such that the underlying issue of the unlawful act is dealt with. Failing this, the recidivism rates will be high, bringing no reformation among juvenile delinquents. Additionally, the juvenile justice system will then merely serve as a tool to empower juvenile delinquency, with the assurance of evading any repercussions.

VI. Pune porsche accident: background and analysis

The Pune Porsche Case, which occurred in 2024, is a controversial case involving juvenile delinquency. Comprising elements of negligence, over-speeding and drunk driving by a teenager, and causing the death of two individuals, it sparked massive outrage across the country, and strong calls for reform. The investigation revealed the role of his family in encouraging him to drive despite his drunken state.¹⁴ However, the most controversial aspect was the bail conditions set by the JJB—writing a 300-word essay on accidents, painting traffic awareness boards, working with a traffic constable, and attending counselling—who, despite the severity of the case, granted bail within merely 14 hours.

One of the major arguments against the aforementioned decision was that it did not reflect the severity of the actions of the juvenile, who neglected his duty of care towards the pedestrians and the other commuters. Thus, such a minimal repercussion shielded him from any accountability. Further, his family’s consistent attempts to absolve him of the crime showcased influence of socioeconomic privilege in obstructing justice, further fueling public outrage.¹⁵ A culmination of all these factors caused the public to opine that the juvenile should have been tried as an adult instead.

However, a closer examination of the law reveals that punitive measures cannot be invoked against the 17-year-old, as none of the relevant sections qualify as heinous offences.¹⁶ Instead, the involved offences were either serious or petty in nature. Since such provisions address offences caused by negligence rather than intentional harm, and do not meet the threshold for categorization as heinous offences, Section 18 of the JJ Act, 2015, applies in this case instead of Section 15. Hence, it would be difficult to try him as an adult.

Additionally, an investigation by the Women and Child Department uncovered multiple procedural discrepancies.¹⁷ One of the primary concerns, as stated by an official was, “The police had mentioned section 304 (culpable homicide not amounting to murder) but it was overlooked while the order was issued by the board member,” inclusion of which could have resulted in stricter measures.¹⁸ According to the IPC, an offence under section 304, can result in the “imprisonment of either description for a term which may extend to ten years, or with fine, or with both, if the act is done with the knowledge that it is likely to cause death, but without any intention to cause death, or to cause such bodily injury as is likely to cause death.”¹⁹ This possession of knowledge can be inferred from the juvenile’s insistence on driving the car, despite his driver’s warnings. Yet, the application of this section does not guarantee punitive action against the juvenile, as it lacks a prescribed minimum punishment. The abovementioned reasoning was also upheld by the Supreme Court in the 2016 Mercedes hit-and-run case involving a juvenile, wherein the juvenile could not be tried as an adult, as the crime did not fall under the broader classification of ‘heinous offences,’ which requires imprisonment of at least seven years.²⁰

Since there have not been any legislative actions to address the loopholes mentioned above, there should have been an emphasis on the imposition of effective rehabilitative efforts. However, in this scenario, wherein power has been misused, and an act of negligence has unfairly cost the lives of two young individuals, such minimal rehabilitative measures cannot serve the purpose of the law. Further, his family’s unlawful attempts to establish his innocence may misguide him to believe the absence of consequences to his actions, because of his wealth and connections. Such behaviour can also contribute to a rise in the recidivism rate. Hence, in the present juvenile justice system where reformation is the primary objective, the absence of a positive role model and the application of a minimal rehabilitative approach, the goal might be diluted. The importance of the existence of the former factor is well explored in the book ‘The Other Wes Moore: One Name, Two Fates,’²¹ in which the author draws parallels between his life and a man who shared not only the same name, but also a similar background and set of circumstances. It emphasised the impact of having a positive role model in shaping the trajectory of the life of a child. In the absence of such positive influences, a minimal rehabilitative technique, as seen in the Pune Porsche Case, might fail to impart the essence of values like accountability, necessary to transform the juvenile into a responsible adult.

VII. Comparative analysis with the ethan couch case

The Ethan Couch Case in the US involved a drunk sixteen-year-old whose reckless driving resulted in the death of four individuals and serious injury of two. Similar to the Pune Porsche Case, the accused was an affluent juvenile who caused the accident while under the influence of alcohol. He used the legal defence strategy of ‘affluenza’ (the role of wealth as an illness, alienating the rich from the ability to differentiate between right and wrong, and hindering them from foreseeing the consequences of their actions) to shield himself from any accountability. Ultimately, the judge sentenced him to 10 years of probation and time in a rehab facility.²²

This paper argues that probation would have been a more suitable measure in the Pune Porsche Case too, due to the stark similarities between the two. This is because the concept of ‘probation,’ a non-custodial alternative, particularly suitable for first-time offenders of serious crimes, aims to correct the behaviour of juveniles without alienating them from their communities.²³ Thus, it delicately balances both accountability and rehabilitation. It is achieved by ensuring that the juvenile meets certain terms and conditions- including counselling, curfews, reporting to a probation officer, etc.²⁴

Further, this aligns with the provisions mentioned under section 18 of the JJ Act, 2015, which directs the ‘child in conflict with the law’ to be released on probation, for good conduct, not exceeding a period of 3 years for a juvenile committing a serious offence, under the care of their parents, guardians or any facility deemed fit for ensuring the good conduct of the child.²⁵ Given the lack of a strong positive influence in his life, placing the juvenile on probation under the care of a fit facility specifically tailored to address the underlying issues in this case, could have been a more effective approach, as this would align with the core objective of reformation embodied in the JJ Act, 2015.

It is crucial to remember that the imposition of probation as a suitable rehabilitative measure may not necessarily yield a positive result. To ensure that probation truly plays a transformative role, it must be handled cautiously. Firstly, during the probation period, the underlying issues triggering the unlawful actions of the delinquent must be addressed and resolved. Secondly, meaningful and realistic goals should be set to decrease the possibility of reoffending, while making room for some missteps. Thirdly, it is preferable if the parents of the juvenile are actively involved in the process, as ultimately, they play a major role in shaping the trajectory of their child’s life by imparting crucial values. Engaging parents in this process can potentially contribute to the reinforcement of positive behaviour and attitude.²⁶

VIII. Recommendations

1. Incorporate International Models: The Indian juvenile justice system could incorporate elements of some international models, particularly those of the Scandinavian countries known for their low recidivism rates, such as Norway, which has a recidivism rate of 20% (based on re-conviction within two years). The punishments imposed by Norway are deeply rooted in their rehabilitative approach, enabling ex-convicts to smoothly reintegrate into society. Prior to the introduction of these measures, Norway’s recidivism rate was as high as 60-70%.²⁷ The success of these reforms is attributed to the educational opportunities and vocational training provided to those serving a sentence, enabling them to smoothly navigate life outside prison. The environment in the prison is also set up to replicate life outside prison, reinforcing a sense of normalcy and freedom.²⁸ Thus, perfectly balancing accountability and reintegration. As the Indian juvenile justice system primarily aims to rehabilitate delinquents, it could benefit from incorporating the Norwegian system’s measures by prioritising the role of educational opportunities and vocational training in the reformation process through consistent efforts and uniform application.

2. Proportionality in Judgement and Legal Amendments: Juveniles must be held accountable for their actions, with a verdict proportionate to the unlawful acts of the juvenile. Additionally, the rehabilitative measure must appropriately address the underlying cause for the actions of the juvenile and tackle it. The proportionality of the judgement can be achieved by checking the following:

A. If the juvenile is found to be a repeated offender despite imposition of prior penalties, alternative deterrents must be considered.

B. Address the loophole surrounding how a juvenile must be tried if the prescribed punishment of the crime committed by the juvenile does not have a minimum sentence, like Section 304 of IPC which prescribes a maximum punishment of 10 years, but fails to specify a minimum punishment.

C. If the unlawful act led to a loss of life, then it must be handled delicately. The emotions of the victim’s family, the circumstances surrounding the death, and the involvement of mens rea (including the ability to understand the consequences) must all be considered. While the last factor is examined in cases falling under Section 15 of the JJ Act, it is only applicable to heinous offences. Since drunk driving resulting in death—as seen in the Pune Porsche Case—is a case of negligence, such factors are not necessarily studied. Therefore, a proper procedure must be laid down to deal with non-heinous cases involving the death of a person, which will ensure consistency and fairness in the legal system.

Thus, the various stakeholders in the legal realm must take charge, and certain amendments must be made to deal with the loopholes surrounding cases of juvenile delinquency involving loss of life due to gross negligence, such that the child in conflict with the law is truly reformed into a responsible adult. These amendments can also clearly outline the importance of a proportional verdict by specifying a set of outcomes in various circumstances. Simultaneously, strong emphasis must be placed on the compliance of the existing laws and rules and regulations by juveniles.

3. Prevent Socioeconomic Bias: To uphold the general spirit of the rule of law, according to which, no one is above the law, strict action should be taken to prevent those with a background of affluence from misusing their status and power by manipulating the facts of the case, as such instances essentially undermine the spirit of the legal system. By advocating for a fair and equitable treatment of all juveniles under the law, despite their socioeconomic background, we can ensure that the leniency guaranteed by the juvenile justice system does not undermine the accountability of minors.

4. Community and Institutional Stakeholder Involvement: As previously discussed, having positive role models who can direct a juvenile to lead a life of discipline is crucial. Thus, the active involvement of various community and institutional stakeholders in the rehabilitative process can create a healthy and supportive environment for juveniles. This can include parents, mental health professionals, NGOs, vocational training centres, educational institutes, correctional institutions, etc. Through this involvement, mechanisms for supervision of the juvenile delinquent can be put in place, to ensure they do not sway from the path of honesty. Further, this can help the juvenile fully reform and reintegrate into society as a responsible citizen.

In the Pune Porsche Case, the conditions of the bail received by the juvenile highlighted active participation of various stakeholders as the juvenile was directed to:

1. Assist RTO officials, study traffic rules for 15 days, and submit a report.

2. Appear for de-addiction counselling (for alcohol consumption).

3. Consult a psychiatrist at Sassoon Hospital, and submit a report to the Juvenile Justice Board within 15 days.

4. Parents were required to present him before the Juvenile Justice Board as and when required, and keep him away from 'bad company'.²⁹

Thus, through the above measures, an active involvement of various stakeholders was facilitated to tackle the root cause of the incident. While, on a surface, the overall decision appears to be well-tailored to reform him, “according to the Discovery Institute, one in five people who complete addiction treatment will stay sober during their first year in recovery. This means that nearly 80% of people will relapse at some point during that first year. Additionally, there is a 40% chance of relapse during the first two years of recovery.”³⁰ Although psychiatric intervention may address the underlying trigger of alcoholism, regular supervision and evaluation of the juvenile to monitor his progress, through probation, could provide additional support. To strengthen this argument, a report prepared by the US Courts identifies that Intensive Supervision Programmes (ISP)—involving components like frequent contact with probation officers, random drug testing and electronic monitoring—if combined with treatment-oriented programmes can significantly reduce chances of relapse.³¹ While ISP is not widely used in India, provisions like probation and regular monitoring, mentioned under Section 18 of the JJ Act of 2015 could serve a similar purpose. Thus, reiterating my overall argument of the necessity of probation in cases like the Pune Porsche Case.

IX. Potential challenges

Although backed by statistics and successful implementation in other judicial systems, integrating the above recommendations in India’s juvenile justice system may be a hurdle due to the paucity of resources and lack of infrastructure. Additionally, India’s population is approximately 260 times Norway’s population, presenting a significant difficulty in tailoring rehabilitative approaches to suit the individual needs of each juvenile.

One way to address these challenges is to do a pilot study, which may be scaled up based on its success. Under this study, measures like probation, coupled with treatment-based approaches will only be implemented on a selected group of juveniles fulfilling a particular criteria– seriousness of the crime, mental maturity, and reoffending risk. The progress of these juveniles can be closely monitored by a committee comprising legal experts, law enforcement representatives, government officials, and psychologists to assess the effectiveness of these measures on them. Additionally, resource allocation is crucial to ensure an efficient outcome. If this turns out to be a success, its gradual expansion can help facilitate a sustainable integration into the broader juvenile justice system.

X. Conclusion

To conclude, the JJ Act of 2015, rooted in its rehabilitative approach, raises valid questions regarding accountability. It is crucial that this approach, while maintaining its focus on reintegration, effectively reforms juveniles and ensures accountability for their actions, thereby curtailing their chances of reoffending.

The reformative model incorporated by the Norwegian justice system strongly supports the proposition that closely tailored rehabilitative measures addressing underlying factors can reform juveniles and hold them accountable for their actions. Thus, in the Pune Porsche Case, despite punitive measures not being applicable as per law, specifically tailored rehabilitative measures could have served the dual purpose of accountability and reformation.

By drawing parallels with the Ethan Couch Case, which bears many similarities with the present case, this paper argues how probation—through its mechanisms like monitoring and supervision—may have been a better-suited method. This argument is made after considering several factors like the misuse of wealth as a shield, his family’s role in his unlawful acts, and the absence of positive mentorship.

Finally, the Indian juvenile justice system may adopt various measures including incorporating elements of some international models known for their low recidivism rate, proportional response to the unlawful actions of the juvenile, prevention of socioeconomic bias and active involvement of various stakeholders- legal, community, institutional, etc. Such measures can help achieve the delicate balance between accountability and rehabilitation. In conclusion, various stakeholders—policymakers, legal professionals, concerned institutions, and the community at large—must join hands and collectively help build a safer and more just society, thereby ensuring the juvenile justice system serves as a beacon of justice and is immune from bias.

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Footnotes

1. Author is a Student at Government Law College, Mumbai, India.

2. Nat’l Crime Records Bureau, Crime in India 2022, ch. 5A.1 (Ministry of Home Affairs 2023). ↩

3. Rohit Pradhan, Critical Analysis: Juvenile Justice (Care and Protection of Children) Act 2015, LexForti Legal, (Sept. 13, 2023), https://lexforti.com/legal-news/juvenile-justice-act-2015/ (last visited July 12, 2025). ↩

4. Juvenile Justice (Care and Protection of Children) Act, § 2(45), No. 2, Acts of Parliament, 2015 (India). ↩

5. Id. § 2(54). ↩

6. Id. § 2(33). ↩

7. Id. § 15. ↩

8. Id. § 18(3). ↩

9. Id. § 15. ↩

10. Id. § 18. ↩

11. Laurence Steinberg, Should the Science of Adolescent Brain Development Inform Public Policy?, 23(3) Issues Sci. & Tech. 67 (2009), https://www.jstor.org/stable/43315672 (last visited June 14, 2025). ↩

12. Sudha Yadav & Akhilesh Ranaus, Juvenile Justice Reforms: Evaluating the Effectiveness of Rehabilitation vs Punishment, 5(6) IJFMR (2023), https://www.ijfmr.com/papers/2023/6/9541.pdf (last visited June 14, 2025). ↩

13. Youth.gov, Youth Involved with the Juvenile Justice System, https://youth.gov/youth-topics/juvenile-justice/youth-involved-juvenile-justice-system (last visited June 14, 2024). ↩

14. Gitesh Shelke, Pune Car Crash: Builder Told Driver to Let His Teen Son Drive Porsche, Cops Tell Court, Times of India (May 23, 2024), https://timesofindia.indiatimes.com/city/pune/builder-told-driver-to-let-his-teen-son-drive-porsche-cops-to-court/articleshow/110347400.cms#:~:text=A%2017-year-old%27s%20involvement%20in%20a%20fatal%20car%20crash,to%20drive%20the%20car%2C%20leading%20to%20legal%20consequences (last visited June 14, 2025). ↩

15. Omkar Wable, Pune Porsche Case: Bribe Was Paid at Juvenile Board to Swap Teen’s Blood Sample, India Today (June 12, 2024), https://www.indiatoday.in/india/story/pune-porsche-case-vishal-agarwal-sassoon-hospital-crime-branch-2552436-2024-06-12 (last visited July 14, 2025). ↩

16. Pune Porsche Crash: Why Teen Who Killed 2 Has Been Let Off with Writing an Essay While Father Has Been Detained, Firstpost (May 21, 2024), https://www.firstpost.com/explainers/pune-porsche-crash-teen-killed-2-bail-writing-essay-father-detained-motor-vehicles-act-13773181.html (last visited June 17, 2025). ↩

17. Nisha Nambiar, 300Word Essay Condition: 2 Juvenile Board Members Face Axe for Bail to Teen Accused in Pune Porsche Case, Times of India (July 18, 2024), https://timesofindia.indiatimes.com/city/pune/300-word-essay-condition-2-juvenile-board-members-face-axe-for-bail-to-teen-accused-in-pune-porsche-case/articleshow/111822368.cms (last visited July 20, 2025). ↩

18. Porsche Crash: Panel Probing Two JJB Members Over Minor’s Bail Finds Procedural Lapses, Misconduct, News18 (June 15, 2024), https://www.news18.com/india/porsche-crash-panel-probing-two-jjb-members-over-minors-bail-finds-procedural-lapses-misconduct-8933898.html (last visited June 17, 2025). ↩

19. Indian Penal Code, § 304, No. 45, Acts of Parliament, 1860 (India). ↩

20. 2016 Mercedes HitandRun Case to Be Tried as Juvenile: Supreme Court, NDTV (Jan. 9, 2020), https://www.ndtv.com/delhi-news/2016-mercedes-hit-and-run-case-to-be-tried-as-juvenile-supreme-court-2161539 (last visited June 17, 2025). ↩

21. Wes Moore, The Other Wes Moore: One Name, Two Fates (Spiegel & Grau 2010). ↩

22. ABC News, ‘Affluenza' DUI Case: What Happened Night of the Accident That Left 4 People Dead, (Dec. 31, 2015), ’Affluenza' DUI Case: What Happened Night of the Accident That Left 4 People Dead - ABC News (go.com) (last visited June 17, 2025). ↩

23. D. Trayosha, Probation: A Study in the Indian Context—Probation of Offenders Act, Legal Service India, Probation: A Study In The Indian Context - Probation of Offenders Act (legalserviceindia.com) (last visited June 17, 2025). ↩

24. iResearchNet, Conditions of Parole and Probation, https://criminal-justice.iresearchnet.com/criminal-justice-process/parole-and-probation/conditions-of-parole-and-probation/ (last visited June 17, 2025). ↩

25. Juvenile Justice (Care and Protection of Children) Act, § 18, No. 2, Acts of Parliament, 2015 (India). ↩

26. Annie E. Casey Foundation, Transforming Juvenile Probation: A Vision for Getting It Right 22 (2018), https://assets.aecf.org/m/resourcedoc/aecf-transformingjuvenileprobation-2018.pdf (last visited June 17, 2025). ↩

27. First Step Alliance, Norway Prison System: Lessons (Jan. 3, 2022), https://www.firststepalliance.org/post/norway-prison-system-lessons (last visited June 17, 2025). ↩

28. Meagan Denny, Norway’s Prison System: Investigating Recidivism and Reintegration, 10 Bridges: A J. Student Research 30 (2016),"Norway's Prison System: Investigating Recidivism and Reintegration" by Meagan Denny (coastal.edu) (last visited June 17, 2025). ↩

29. Chandrashekar Srinivasan, With 7 Conditions, Teen Porsche Driver Got Bail on Grandfather’s Assurance, NDTV (May 22, 2024), https://www.ndtv.com/india-news/pune-porsche-crash-the-7-conditions-listed-in-bail-order-of-pune-teen-who-killed-2-techies-5719922 (last visited June 17, 2025). ↩

30. The Source, What Percentage of Addicts Stay Clean After Rehab?, (Apr. 1, 2021), https://www.thesourcetreatmentcenter.com/blog/percentage-of-addicts-that-stay-clean/ (last visited June 17, 2025). ↩

31. U.S. Dep't of Justice, Office of Justice Programs, Report on Intensive Supervision Programs in Probation and Parole 12 (1983). ↩