Complainant's SC/ST Status Alone Cannot Trigger Atrocities Act, Says Supreme Court

News18

27-07-2025

The SC has reiterated that the offence must be committed specifically on grounds of the victim's caste or tribal identity for the Act to apply
The Supreme Court (SC) recently held that the mere fact of a complainant belonging to a Scheduled Caste (SC) or Scheduled Tribe (ST) community is not sufficient to attract the provisions of the Scheduled Castes and the Scheduled Tribes (Prevention of Atrocities) Act, 1989.
The Court has reiterated that the offence must be committed specifically on grounds of the victim's caste or tribal identity for the Act to apply.
The judgment was delivered on July 22, by a bench comprising Justices B.R. Gavai and Sandeep Mehta. The SC was hearing a petition challenging the initiation of criminal proceedings under Section 3(1)(r) of the SC/ST Act, along with sections 294, 323 and 506 of the Indian Penal Code (IPC), arising from a domestic dispute between a man and his estranged wife.
The appellant had approached the SC seeking quashing of the proceedings, arguing that there was no caste-based element to the dispute and that the SC/ST Act had been wrongly invoked. The Madhya Pradesh High Court had earlier declined to interfere with the criminal proceedings.
Setting aside the High Court's order, the Supreme Court clarified that for an offence to fall within the purview of Section 3(1)(r) of the SC/ST Act, there must be a specific intention to insult or intimidate a person belonging to the SC or ST communities, and such conduct must occur in a place within public view. More importantly, the insult or intimidation must be 'on the ground that such person is a member of a Scheduled Caste or a Scheduled Tribe".
The bench observed that the statute cannot be invoked solely because the complainant is a member of a protected community. The underlying motivation behind the alleged act must be to target the individual due to their caste identity. In the absence of such intent, the invocation of the SC/ST Act would not be legally sustainable.
In the present case, the Court found that the allegations arose out of a matrimonial discord and that there was no specific averment or material to show that the alleged abuse or insult was targeted at the complainant because of her caste. The complaint lacked any assertion that the alleged acts were committed with caste-based malice or occurred in public view with the intention of humiliating the complainant on account of her caste.
The Court relied on its earlier decision in Hitesh Verma v. State of Uttarakhand (2020), where it had similarly held that disputes of a purely private nature, such as property or domestic issues, do not attract the provisions of the SC/ST Act unless there is a clear indication of caste-based animus. In that case, the Court had cautioned against the misuse of the protective statute and emphasised that its application must be based on objective facts that demonstrate the commission of an offence specifically aimed at humiliating or oppressing a person due to their SC/ST status.
Reiterating this position, the Court held that allowing the proceedings to continue under the SC/ST Act in the absence of necessary legal ingredients would be a misuse of process and would dilute the purpose of the statute. The judgment underscores the principle that special legislation enacted to protect marginalised communities must be applied with precision and not be extended to situations where its core requirements are not met.
The Supreme Court proceeded to quash the proceedings under the SC/ST Act while leaving the charges under the Indian Penal Code to be decided on merits before the trial court. The decision reiterates the judiciary's approach to ensuring that while the rights of historically oppressed communities must be safeguarded, the criminal law must not be weaponised in situations where the essential statutory conditions are absent.
This court has sifted cases where allegations under the SC/ST Act are made without establishing a direct link to caste-based motivation.
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