The Allahabad High Court has ruled that criminal proceedings under the Scheduled Castes and the Scheduled Tribes (Prevention of Atrocities) Act, 1989, can be quashed on the basis of a compromise if the offense is primarily private in nature and not committed on account of the victim’s caste. While allowing the appeal filed by Rahul Gupta and others, the Court directed the informant to return the compensation amount received from the state authorities.
Case Background
The ruling was delivered in Rahul Gupta And 6 Others v. State of U.P. and Another (Criminal Appeal No. 9930 of 2024). The appellants approached the High Court challenging the entire criminal proceedings, including the charge sheet dated April 30, 2024, and the summoning order dated July 19, 2024, passed by the Special Judge, SC/ST Act, Meerut.
The case arose from Case Crime No. 0126 of 2024 at Police Station Brahampuri, District Meerut, where the appellants were charged under Sections 147, 323, 500, 504, and 506 of the Indian Penal Code (IPC) read with Section 3(2)(va) of the SC/ST Act.
Arguments of the Parties
Counsel for the appellants submitted that the dispute between the parties had been settled amicably. It was argued that the compromise was entered into “without any coercion or undue influence upon the informant of this case and is a result of free will and consent of the parties.”
The Court took on record that, in compliance with an earlier order dated October 22, 2024, the Special Judge, SC/ST Act, Meerut, had verified the compromise vide an order dated December 4, 2024.
Regarding the statutory compensation, a report from the District Magistrate, Meerut, dated December 4, 2024, confirmed that “the opposite party no.2 has not returned the compensation amount to the authority concerned.”
Court’s Analysis and Legal Observation
Justice Shekhar Kumar Yadav, presiding over Court No. 86, analyzed whether a compromise could be accepted in cases involving the SC/ST Act. The Court observed that the matter appeared to be a “purely private dispute” and, prima facie, “the alleged offence has not been committed on account of the caste of the victim.”
The Court placed significant reliance on the Supreme Court’s judgment in Ramawatar v. State of M.P. (2022) 13 SCC 635. Quoting Paragraph 17 of the Apex Court judgment, the High Court noted:
“…where it appears to the Court that the offence in question, although covered under the SC/ST Act, is primarily private or civil in nature, or where the alleged offence has not been committed on account of the caste of the victim… the Court can exercise its powers to quash the proceedings.”
The Court further referred to Paragraph 19 of Ramawatar, emphasizing the need for vigilance to ensure the compromise is voluntary, stating:
“If the Courts find even a hint of compulsion or force, no relief can be given to the accused party.”
Additionally, the Court cited the Full Bench judgment of the Allahabad High Court in Ghulam Rasool Khan And Others vs State Of U.P And Another [2022 (8) ADJ 691], which settled the legal position that a matter under the SC/ST Act “may be compounded in a criminal appeal under section 14-A(1) of SC/ST Act and there is no need to take recourse of U/s. 482 Cr.P.C. for the same.”
Decision and Directions
Noting that the compromise had been verified by the trial court and was free from undue influence, the High Court allowed the criminal appeal. The entire proceedings of Sessions Trial No. 892 of 2024, along with the summoning order and charge sheet, were quashed.
However, the Court imposed a strict condition regarding the state funds disbursed to the alleged victim. The judgment concluded with the direction:
“The opposite party no.2 is directed to returned the compensation amount received from the authority concerned within a week from today.”
The judgment was delivered on November 4, 2025.
