The Supreme Court docket on Thursday (20.08.2026) quashed proceedings below Sections 3(2)(r) and three(1)(s) of the Scheduled Castes and the Scheduled Tribes (Prevention of Atrocities) Act. 1989 (SC/ST Act). The case was filed in opposition to a college supervisor, accusing him of assaulting and hurling caste-based abuses on the father of two college students. The Supreme Court docket quashed the case, holding that the alleged utterances have been made inside an enclosed room with no public entry, and due to this fact didn’t fulfill the important statutory requirement.
A bench of Justice Vikram Nath and Justice Sandeep Mehta dominated so whereas listening to an attraction in opposition to a judgment handed by the Allahabad Excessive Court docket, which had dismissed the appellant’s attraction below Part 14A(1) of the SC/ST Act.
The appellant was the Supervisor of the college the place the respondent’s (R2) sons studied. Following a quarrel between two college students, R2 approached the appellant, who allegedly abused and assaulted him together with the school-staff, and used caste-based abuses in opposition to him. An FIR below Sections 147, 323, 342, and 504 of the Indian Penal Code, 1860 (IPC, now , Sections 191, 115, and 352 of the Bharatiya Nyaya Sanhita, 2023) and Sections 3(1)(r) and three(1)(s) of the SC/ST Act, was lodged in opposition to the appellant. A chargesheet was filed in opposition to him and the Particular Decide took cognisance.
It’s to be famous {that a} cross-FIR was additionally lodged the identical day by the appellant’s spouse in opposition to R2, alleging that he had abused and assaulted her within the faculty workplace, following which the appellant intervened and was himself assaulted. A chargesheet was filed in opposition to R2 and cognisance was taken.
The appellant challenged the Particular Decide’s summoning order earlier than the Allahabad Excessive Court docket, which rejected his plea, holding that merely that the current case was a counterblast couldn’t, by itself, be a floor for quashing and {that a} prima facie case was made out on materials out there. Aggrieved by the Excessive Court docket’s discovering, the appellant approached the Supreme Court docket.
Earlier than the Supreme Court docket, the appellant contended that the Excessive Court docket had erred in holding that the incident occurred inside public view. It was submitted that the witness statements didn’t set up that anybody was current contained in the room on the time of incident, and that the room was enclosed and had no window or public entry. It was additionally submitted that the FIR itself contained no particular allegation attributing caste-based abuses to the appellant, and that he had no prior information of his caste.
Quite the opposite, the respondent relied on the Excessive Court docket’s judgment to contend that the incident occurred inside public view and that there was enough materials on file to determine such a case.
Perusing Sections 3(1)(r) and three(1)(s) of the SC/ST Act, the Supreme Court docket famous that the core query was whether or not the fabric on file disclosed that the alleged caste-based abuses have been uttered at a spot inside public view. Counting on its determination in Karuppudayar v State (represented by the Deputy Superintendent of Police, Lalgudi, Trichy) & Ors and Hitesh Verma v State of Uttarakhand, the bench reiterated, “it may thus be seen that, to be a spot ‘inside public view’, the place must be open the place the members of the general public can witness or hear the utterance made by the accused to the sufferer. If the alleged offence takes place throughout the 4 corners of the wall the place members of the general public will not be current, then it can’t be stated that it has taken place at a spot inside public view.”
Making use of this, the Court docket noticed that the FIR didn’t state that the alleged abuses have been uttered within the presence or listening to of members of the general public. It additionally famous the absence of any particular allegation of caste-based abuse neither within the FIR nor in R2’s statements. “The fabric relied upon by the prosecution, on the highest, discloses a quarrel and scuffle between the events. It doesn’t disclose any particular caste-based utterance attributable to the appellant,” the bench noticed.
Inspecting the statements of witnesses (faculty academics), the Court docket noticed that whereas they described an “altercation and scuffle”, none of them acknowledged that they have been current when the alleged caste-based abuses have been uttered or they heard any of them. “Their mere presence within the faculty premises, due to this fact, doesn’t set up that the alleged utterance was made inside public view,” it was held.
The bench clarified that whereas the Court docket will not be required to conduct a meticulous appreciation of proof on the stage of cognisance, “the fundamental elements of the offence should emerge from the fabric positioned earlier than the Court docket.”
Holding that the offences below the SC/ST Act weren’t prima facie made out, the Supreme Court docket put aside the Excessive Court docket’s judgment and quashed the proceedings below the Act. The Court docket, nevertheless, clarified that the proceedings in respect of offences below the IPC would proceed.
Case : Ramkrishna Chauhan v State of Uttar Pradesh & Anr
Quotation : 2026 LiveLaw (SC) 837
Look:
For Appellant: Mr. Siddharth Aggarwal, Adv.
For Respondent: Ms Anushree Prashit Kapadia, Adv.
