Did the Supreme Court Just Quash an SC/ST Case Against a Bihar Man?
Synopsis
Key Takeaways
- Supreme Court quashes SC/ST case against Bihar man.
- Mere presence and vague allegations deemed insufficient.
- The ruling emphasizes the need for substantial evidence.
- Highlights the importance of protecting individual rights.
- Sets a precedent for future legal proceedings.
New Delhi, Jan 19 (NationPress) The Supreme Court has overturned the criminal proceedings against a man from Bihar, who was accused under the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act. The court emphasized that mere presence at the incident location and vague claims are inadequate for prosecution. A Bench comprising Justices J.B. Pardiwala and Alok Aradhe annulled a decision made by the Patna High Court, which had declined to intervene in the trial court's cognizance and summoning order from Bhagalpur.
In granting the appeal submitted by Keshaw Mahto, the Justice Pardiwala-led Bench noted the state government's counsel's assertion that 'besides being present at the location with co-accused, there are no specific overt actions linked to him.'
While dismissing the prosecution, the Supreme Court stated that 'subjecting the appellant to trial alongside other co-accused would amount to a travesty of justice.'
The case originated from a 2019 FIR where the complainant, a member of a Scheduled Caste, alleged he was verbally and physically assaulted at an anganwadi center, with caste-related insults being thrown at him.
On October 9, 2020, the trial court acknowledged the offenses under various sections of the IPC and Sections 3(1)(r) and 3(1)(s) of the SC/ST Act.
The appellant contested the cognizance and summons order at the Patna High Court under Section 14A of the SC/ST Act, but his appeal was rejected, leading him to approach the Supreme Court.
In its ruling, the apex court reiterated that violations under Sections 3(1)(r) and 3(1)(s) of the SC/ST Act do not apply solely based on the complainant's Scheduled Caste or Scheduled Tribe status.
The Justice Pardiwala-led Bench stated, 'The mere fact that the complainant is from a Scheduled Caste or a Scheduled Tribe is insufficient,' adding that any insult or intimidation must be 'due to the person's membership in a Scheduled Caste or a Scheduled Tribe.'
Additionally, the court indicated that 'even having knowledge that the complainant belongs to a Scheduled Caste or a Scheduled Tribe does not suffice to invoke Section 3(1)(r).'
The Supreme Court clarified that simply abusing someone or mentioning a caste name does not constitute an offense under Section 3(1)(s) of the SC/ST Act.
It elaborated that 'merely insulting a member of a Scheduled Caste or a Scheduled Tribe is inadequate. At the same time, uttering a caste name does not equate to committing an offense,' asserting that only when the insult is 'laced with the caste name' and intended to demean will it attract legal repercussions.
Upon reviewing the FIR and the chargesheet, the apex court found no claims suggesting that the appellant had used caste-related language or acted with the intent to demean the complainant.
It stated, 'Neither the FIR nor the chargesheet includes any indication of insult or intimidation by the appellant, let alone with the intent to demean the complainant.'
The apex court also determined the IPC allegations to be ambiguous and lacking essential elements, noting that 'the mere presence of the appellant does not confirm his involvement in the alleged crime.'
Concluding that no prima facie case existed against the appellant under either the SC/ST Act or the IPC, the Supreme Court granted the appeal and dismissed the criminal proceedings against him.
'In light of the above, this appeal is successful and hereby approved. The challenged order from the High Court is annulled, and the criminal prosecution against the appellant is dismissed,' ordered the Justice Pardiwala-led Bench.