Supreme Court Quashes Trial Under SC‑ST Act Where Abuse Occurred Inside Officer's Office, Not Within Public View

A bench of Justices B.R. Gavai and Augustine George Masih heard appeals against the judgment and final order of the Single Judge of the Madras High Court, which had dismissed petitions under Section 482 CrPC seeking to quash criminal proceedings instituted under Sections 3(1)(r) and 3(1)(s) of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989 read with relevant IPC provisions. The appeals arose from Special Leave Petitions against the High Court’s refusal to quash Special S.C. No.7 of 2022 pending before the I‑Additional District and Sessions Judge (PCR), Tiruchirappalli.

The Court allowed the appeals, set aside the High Court order and quashed the charge‑sheet and all proceedings arising from Special S.C. No.7 of 2022. The Court held that, taking the FIR allegations at their face value, the essential ingredients of offences under Sections 3(1)(r) and 3(1)(s) of the SC‑ST Act were not made out because the incident occurred within the complainant’s office and not at a “place within public view.” The Court emphasised settled principles that the extraordinary power under Section 482 CrPC must be exercised sparingly but is available where the FIR, even if accepted in entirety, does not prima facie disclose an offence. The Court, in its reasoning, observed: “We find, as already observed herein, that the allegations made in the FIR, even if they are taken at their face value and accepted in their entirety, do not prima facie constitute an offence either under Section 3(1)(r) or under Section 3(1)(s) of the SC‑ST Act. We are of the considered view that the case would fall under the first category, listed by this Court in Paragraph 102 in the case of Bhajan Lal (supra).”

Background The prosecution alleged that on September 2, 2021 the appellant went to the Revenue Divisional Office to enquire about his father’s petition for inclusion in a patta. A quarrel ensued and the appellant allegedly abused the Revenue Inspector by calling him a caste name and using vulgar words while the complainant was at his office desk. The Revenue Inspector lodged a complaint; Crime No.676 of 2021 was registered and a charge‑sheet was filed for offences under Sections 294(b) and 353 IPC read with Sections 3(1)(r) and 3(1)(s) of the SC‑ST Act. The appellant moved the Madras High Court under Section 482 CrPC to quash the proceedings; the Single Judge dismissed the petitions on the view that trial could proceed.

Before the Supreme Court, counsel for the appellant contended that, even on the FIR’s averments, the ingredients of Sections 3(1)(r) and 3(1)(s) were not satisfied because the assaultive language was not used in a place within public view. The respondents relied on the charge‑sheet and investigative material. The Court examined earlier authorities including Swaran Singh and Hitesh Verma on the meaning of “place within public view” and reiterated the distinction that “a place can be a private place but yet within the public view,” while noting that an offence committed inside a closed chamber where no public was present did not ordinarily fall within the SC‑ST Act’s public‑view requirement. The Court applied the categories in State v. Bhajan Lal to conclude that the FIR, even if accepted, did not prima facie disclose the statutory offences and therefore warranted quashing.

Disposition: Appeals allowed; judgment and order dated 28.02.2024 of the Madras High Court set aside; the charge‑sheet and all proceedings in Special S.C. No.7 of 2022 were quashed. Pending applications stood disposed of.

Case Details: Case No.: 2025 INSC 132 Case Title: Karuppudayar v. State rep. by the Deputy Superintendent of Police, Lalgudi, Trichy & Ors. Appearances: For the Petitioner(s): Smt. Vanshaja Shukla, Advocate (for Appellant) For the Respondent(s): Shri Sabarish Subramanian, Advocate (for Respondents)