Maggie Atkinson, who was appointed last autumn, has argued that children under 12 should not be treated as criminals under the law.Dr Atkinson said: "Even the most hardened of youngsters who have committed some very difficult crimes are not beyond being frightened."
She argued that the fact that Jon Venables, who was convicted of two-year-old Jamie Bulger's murder at the age of 10, has recently been recalled to custody should force a rethink of the system.
Dr Atkinson told the The Times that politicians should not be swayed too much by the emotional pleas of victims' familes.
"The "we are too worried about the parents issue" is something that runs like a thread through a number of cases," she said. "My constant song is "listen to the children and young people"."
She made the comments the same week that Denise Fergus, Jamie Bulger's mother, met with Jack Straw, the Justice Secretary.
Dr Atkinson said: "None of us is born a good persn or an evil person. The backgrounds from which we come, and whether we are nurtured and secure, will shape our character."