The Delhi High Court has quashed an FIR registered against Ranjit Kaur, an Associate Professor at Lakshmibai College (Delhi University), under the Scheduled Castes and the Scheduled Tribes (Prevention of Atrocities) Act, 1989, and the Indian Penal Code. The Court observed that the caste-based allegations appeared to be a “belated addition” to an administrative dispute and lacked the necessary specificity to constitute an offence under the special Act.
Background of the Case
The matter originated from an incident on August 16, 2021, during a departmental meeting at Lakshmibai College regarding National Assessment and Accreditation Council (NAAC) preparations. The Petitioner, Ranjit Kaur (Associate Professor in-Charge), and the Respondent No. 2, Dr. Neelam (also an Associate Professor), were involved in an altercation over the signing of the Minutes of the Meeting.
According to the Petitioner, Dr. Neelam refused to sign the minutes immediately, leading to a physical struggle over the attendance register. Conversely, the Complainant alleged that the Petitioner pressured her to sign without reading and subsequently slapped her in front of colleagues.
Arguments by the Parties
The Petitioner sought the quashing of FIR No. 0512/2021, arguing that the complaint was “manifestly attended with mala fides” and instituted to wreak vengeance. She highlighted that the initial handwritten complaints made by the Respondent No. 2 to the Principal and the Police on the day of the incident contained no mention of casteist remarks or humiliation based on her Scheduled Caste (SC) status.
Respondent No. 2 (Complainant) contended that she was physically and mentally humiliated. She stated that while her initial complaints focused on the physical assault, she later detailed the caste-based atrocities in subsequent communications. She alleged that the Petitioner had a long-standing “casteist attitude” and had previously made derogatory remarks regarding “quota beneficiaries.”
Court’s Analysis
The Court, presided over by Justice Neena Bansal Krishna, meticulously examined the timeline of the complaints. It was noted that the first two handwritten complaints (dated August 16, 2021) only mentioned the physical altercation and the slap.
The Court observed:
“The caste element appears for the first time only in the Complaint dated 17.08.2021 to the Principal, as a belated addition to an already narrated version of events.”
Furthermore, the Court analyzed the statements recorded under Section 161 and 164 of the Cr.P.C. It found that only one witness, Dr. Poonam Rani, attributed specific casteist slurs to the Petitioner, whereas the Complainant herself referred to the remarks in “vague and general terms.”
Regarding the legal requirements of the SC/ST Act, the Court stated:
“For an offence to be made out under Section 3 of SC/ST Act, it is essential that the alleged act must have been committed with the intent to humiliate the victim, specifically on account of her caste identity… The nexus between the alleged act and the caste identity of the victim, must be clearly and unequivocally established from the very face of the Complaint.”
The Court found that the genesis of the dispute was an “administrative disagreement” and that the statement of a single witness, which the Complainant did not specifically corroborate in her own statements, could not form the basis of a charge under the Act.
Regarding the charges under Sections 323 (voluntarily causing hurt) and 504 (intentional insult) of the IPC, the Court held that these are non-cognizable offences. Under Section 155(2) of the Cr.P.C., an FIR cannot be registered for such offences without a Magistrate’s order. The Court also noted that a Non-Cognizable Report (NCR) had already been registered for the Section 323 allegation on the day of the incident.
The Decision
Justice Neena Bansal Krishna concluded that the FIR could not be sustained. The Court allowed the petition and quashed FIR No. 0512/2021 registered at P.S. Bharat Nagar, along with all consequential proceedings.
The Court clarified that the Complainant remains at liberty to “avail the appropriate remedy in accordance with law” regarding the allegations under the Indian Penal Code.
Case Details Block:
- Case Title: Ranjit Kaur vs. State N.C.T. of Delhi & Anr.
- Case No.: W.P.(CRL) 1622/2021 & CRL.M.A. 13581/2021
- Bench: Justice Neena Bansal Krishna
- Date: April 01, 2026
