Supreme Court quashes SC/ST Act charges where record lacks caste-specific averments, remits remaining IPC counts to trial court

A bench of Justices Sanjay Karol and Nongmeikapam Kotiswar Singh heard an appeal by an accused challenging the High Court’s affirmation of an order that had framed charges against him arising from a mass disturbance at a public installation ceremony. The sole point before the Court concerned the subsistence of charges under the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989 (SC/ST Act).

The Court allowed the criminal appeal in part, quashing the charges framed under Sections 3(2)(v) and 3(2)(va) of the SC/ST Act against the appellant and remitting the matter to the trial court to proceed on the remaining charges under the Indian Penal Code. The Court held that the High Court had failed to independently examine whether the statutory ingredients of the SC/ST Act were prima facie established and found that the material on record did not disclose the required knowledge or caste-motivated element. The Court, in its reasoning, observed: "In view of the requirements of the sections proposed to be charged, as discussed in para 9 of this Judgment, 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. There does not appear to be any other material on record either, to establish knowledge on part of the accused. Once the knowledge on part of the alleged offender is in question, it is but certain that the charge cannot stand." The Court further emphasised that "Discharge, in that sense, is not a technical indulgence but an essential safeguard."

Background

The dispute arose from an incident on 15 November 2022 at Bachhadapara during the unveiling of a statue of Birsa Munda, where members of an organisation (JAYS) allegedly intercepted vehicles carrying MPs, MLAs and officials, leading to scuffles and stone-pelting. The FIR (No. 0653 of 2022) named multiple persons including the present accused, Dr Anand Rai, and recorded injuries to a security personnel, Sandeep Chandel; a video of the incident was also said to have been provided to police. The chargesheet (Chargesheet No.1 of 2023) charged the accused with multiple IPC offences and, for some accused, provisions of the SC/ST Act as amended.

At committal stage the trial court partly allowed the accused’s discharge application and framed charges under several IPC provisions read with Section 149 IPC and under Sections 3(2)(v) and 3(2)(va) of the SC/ST Act against Dr Anand Rai. The trial court however found that allegations under Sections 3(1)(r) and 3(1)(s) (casteist slurs/abusive language) were not supported by statements under Section 161 CrPC and acquitted the accused under those particular counts. The High Court dismissed the appeal against framing, holding the trial court had applied correct principles, but its sixteen‑page order did not deal substantively with the SC/ST Act charges.

Before the Supreme Court the appellant contested the sustenance of the SC/ST Act charges. The Court reviewed statutory requirements of Sections 3(2)(v) and 3(2)(va)  which require commission of specified IPC offences against a person known to be a member of an SC/ST (or property belonging to such member)  and the settled jurisprudence governing framing and discharge under Sections 227–228 CrPC. Applying the established standard that prima facie ingredients must be discernible from the prosecution material, the Court found absence of any clear averment that the complainant was a member of SC/ST or that the accused had knowledge of caste identity; it therefore concluded the ingredients for the SC/ST Act were not prima facie made out. The Court quashed those charges and remitted the remainder of the case to the trial court, clarifying that this order did not constitute any comment on the other charges.

Case Details:
Case No.: 2026 INSC 141
Case Title: Dr. Anand Rai V. State Of Madhya Pradesh & Anr.
Appearances:
For the Petitioner(s): Mr. Kapil Sibal, Senior Counsel
For the Respondent(s): Mr. Pashupati Nath Razdan, Advocate-on-Record