The Allahabad High Court has delivered a notable judgment clarifying the scope of its inherent powers under Section 482 of the Code of Criminal Procedure (Cr.P.C.) in cases under the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989 (SC/ST Act). The court ruled that inherent jurisdiction can be invoked to challenge entire proceedings, especially when continuance of such proceedings would result in abuse of the judicial process.
The judgment, rendered by a division bench comprising Justice Siddhartha Varma and Justice Vinod Diwakar, provides a nuanced interpretation of the interplay between the Cr.P.C. and the special provisions under the SC/ST Act.
Background of the Case
The ruling arose from a batch of applications led by Abhishek Awasthi @ Bholu Awasthi vs. State of Uttar Pradesh and Another (Case No. 8635 of 2023). The applicants sought to quash proceedings initiated under the SC/ST Act, arguing that the allegations were frivolous and stemmed from civil disputes mischaracterized as criminal offenses.
The applicants contended that while Section 14-A of the SC/ST Act provides for a statutory appellate remedy, it does not preclude the High Court from exercising its inherent powers under Section 482 Cr.P.C. to prevent abuse of legal processes.
Key Legal Issues
The court addressed the following pivotal questions:
1. Can the High Court entertain an application under Section 482 Cr.P.C. to quash proceedings under the SC/ST Act where no interlocutory orders are challenged?
2. Does the availability of a statutory appeal under Section 14-A of the SC/ST Act oust the inherent jurisdiction of the High Court?
3. Is there a judicial conflict in earlier decisions requiring clarification by a larger bench?
Court’s Observations
The division bench delved into precedents from the Supreme Court and its own Full Bench decisions, including:
– Ramawatar vs. State of Madhya Pradesh (2022) 13 SCC 635, where the Supreme Court held that proceedings under the SC/ST Act could be quashed in cases involving civil disputes.
– Ghulam Rasool Khan vs. State of U.P. (2022), where a Full Bench of the Allahabad High Court opined that the inherent jurisdiction of the High Court is not barred by Section 14-A of the SC/ST Act but should be sparingly exercised.
The court distinguished between cases where statutory remedies exist and those where proceedings amount to an abuse of process. It emphasized that the inherent powers under Section 482 Cr.P.C. are meant to ensure justice and cannot be ousted by procedural provisions in special laws.
Important Judicial Observations
The court made the following key observations:
– “The powers under Section 482 Cr.P.C. are all-encompassing and can be exercised to quash proceedings under special statutes like the SC/ST Act when the allegations are civil in nature or when continuance of proceedings would result in a miscarriage of justice.”
– “The availability of an appellate remedy under Section 14-A does not operate as an absolute bar to invoking the High Court’s inherent powers.”
– “Cases involving mala fide intentions, civil disputes disguised as criminal cases, or blatant abuse of legal provisions warrant interference to secure the ends of justice.”
Decision
The bench held that applications under Section 482 Cr.P.C. are maintainable to challenge entire proceedings under the SC/ST Act, provided the applicant demonstrates that continuation of the case would constitute an abuse of process. It clarified that while the inherent jurisdiction is not barred, its exercise must be judicious and reserved for exceptional circumstances.
