The Supreme Court of India has quashed the charges framed against an accused under the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989, ruling that the material on record failed to establish the necessary ingredient of “knowledge” that the victim belonged to a Scheduled Caste or Scheduled Tribe. The Division Bench, comprising Justice Sanjay Karol and Justice Nongmeikapam Kotiswar Singh, remitted the matter back to the Trial Court to proceed with the trial for offences under the Indian Penal Code (IPC).
The Court observed that “to allow a matter to proceed despite the absence of a prima facie case is to expose a person to the strain, stigma, and uncertainty of criminal proceedings without legal necessity,” adding that “the process itself can become the punishment if this responsibility is not exercised with care.”
Background of the Case
The appeal arose from a judgment of the High Court of Madhya Pradesh at Indore, dated July 3, 2025, which had dismissed the appellant’s appeal against the framing of charges. The case originated from an FIR registered on November 15, 2022, at Police Station Bilpank, District Ratlam.
According to the prosecution, a large congregation had gathered at Bachhadapara for the unveiling of a statue of Bhagwan Birsa Munda. The complainant alleged that members of the JAYS organisation intercepted vehicles of public officials, engaged in scuffles, and pelted stones, resulting in injuries to a security person. The appellant was named in the FIR along with others.
Upon completion of the investigation, a chargesheet was filed, and the Special Judge framed charges against the appellant under Sections 147, 341, 427, 353, 332, 333, 326, 323, 352 read with 149 of the IPC, and Sections 3(2)(v) and 3(2)(va) of the SC/ST Act. The appellant’s application for discharge under Section 227 of the Code of Criminal Procedure (CrPC) was allowed only in part by the Trial Court, a decision subsequently affirmed by the High Court.
Arguments and Legal Issues
The primary challenge before the Supreme Court was restricted to the subsistence of charges under the SC/ST Act. The appellant contended that the essential ingredients for offences under the Act were missing. Specifically, it was argued that the FIR and the Final Report were silent on the use of any derogatory or casteist words, and there was no specific averment regarding the use of casteist terms against the original complainant.
The appellant pointed out that for charges under Sections 3(2)(v) and 3(2)(va) of the SC/ST Act, the prosecution must demonstrate that the offence was committed against a person knowing that such person is a member of a Scheduled Caste or a Scheduled Tribe.
Court’s Analysis and Observations
The Supreme Court scrutinized the Trial Court’s order and noted a contradiction. The Trial Court had acquitted the accused of charges under Sections 3(1)(r) and 3(1)(s) of the SC/ST Act (relating to intentional insult and abuse) because none of the witnesses had specifically stated which accused used casteist slurs. However, the Trial Court proceeded to frame charges under Sections 3(2)(v) and 3(2)(va) based on the same evidence.
Justice Karol, authoring the judgment, observed:
“We are at a loss to understand that when the Trial Court itself acknowledges that none of the statements under Section 161 CrPC, state the specific slurs uttered by the accused with the intent to insult threaten or kill, then how is it found, on the same bundle of evidence, and with the same level of scrutiny thereof, that the alleged acts of the accused were informed by caste awareness.”
The Bench held that there was no material on record to establish “knowledge” on the part of the accused regarding the caste of the victim. The Court further noted that there was no averment that the complainant was a member of the SC/ST community.
“Once the knowledge on part of the alleged offender is in question, it is but certain that the charge cannot stand,” the Court stated.
The Supreme Court also criticized the High Court for failing to exercise its jurisdiction as a first appellate court under Section 14-A of the SC/ST Act. The Bench reiterated that an appeal under this section requires the High Court to independently evaluate the material on record and not merely act in a mechanical manner.
“A mechanical affirmation of the order of the Special Court, without independent scrutiny, would therefore be inconsistent with settled appellate jurisprudence and would amount to a failure to exercise jurisdiction,” the judgment read.
The Court emphasized the duty of courts at the stage of framing charges, warning against mechanical prosecution.
“Discharge, in that sense, is not a technical indulgence but an essential safeguard… Fidelity to the rule of law requires the Court to remember that the process itself can become the punishment if this responsibility is not exercised with care.”
Decision
The Supreme Court allowed the appeal to the extent of quashing the charges under the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989. The matter has been remitted to the Trial Court to proceed in accordance with law regarding the charges framed under the Indian Penal Code.
The Court clarified that its decision should not be construed as a comment on the merits of the charges other than those under the SC/ST Act.
Case Details:
Case Title: Dr. Anand Rai v. State of Madhya Pradesh & Anr.
Case No: Criminal Appeal arising out of SLP (Crl.) No. 10711 of 2025
Bench: Justice Sanjay Karol and Justice Nongmeikapam Kotiswar Singh
