Allegations of Caste-Based Targeting Must Be Specific and Supported by Evidence: Supreme Court Upholds Quashing of SC/ST Act Charges

“Merely belonging to a Scheduled Caste cannot be the sole ground for prosecution—intent to humiliate on account of caste must be clearly alleged and proved.” - Supreme Court Dismisses Appeal Against Quashing of Criminal Proceedings Under SC/ST Act, Says No Prima Facie Caste-Based Offence Made Out.

In a notable ruling delivered on 23 July 2025, the Supreme Court affirmed the High Court's decision to quash criminal proceedings under the Scheduled Castes and the Scheduled Tribes (Prevention of Atrocities) Act, 1989, citing lack of evidence of caste-based targeting or mala fide intent.

A Bench comprising Justice B.R. Gavai and Justice Augustine George Masih held that criminal law cannot be used as an instrument of personal vengeance, and emphasized that the essential ingredients of the offences under the SC/ST Act were not satisfied, particularly the requirement of caste-based intent.

“A Dispute Between Two SC Groups Cannot Be Construed As Caste-Based Atrocity”: Court Rejects Intra-Caste Allegation as Misuse of the Act

The origin of the case lay in a land allotment dispute in Duvva village, where the Appellant, a government employee, objected to alleged manipulation of SC-reserved plots by a Mandal Revenue Officer (Respondent No. 2), who allegedly diverted them to persons belonging to the Kapu community.

Subsequently, the Appellant was named in a group clash FIR involving only Scheduled Caste groups, and was later suspended from service. The Appellant alleged that he was falsely implicated by Respondent No. 2 in collusion with a local theatre owner (Accused No. 3) and a police officer (Respondent No. 1) in retaliation for exposing the wrongful allotment.

The Supreme Court, however, observed: “Since it was admittedly a dispute between two groups belonging to the Scheduled Caste, and the clash was not with any other community, involvement of the Appellant because of him being a Scheduled Caste in the criminal case does not arise, what to say of mala fide.” [Para 21]

“False Allegations Filed with Oblique Motives Must Be Quashed at the Threshold”: SC Reiterates Safeguards Against Misuse of the SC/ST Act

Referring to its earlier decisions, including Masumsha Hasanasha Musalman v. State of Maharashtra and Dr. Subhash Kashinath Mahajan v. State of Maharashtra, the Court reiterated the caution against weaponization of the SC/ST Act for settling personal scores.

“An alarming increase in false complaints under the SC/ST Act, particularly against public servants, cannot be ignored. Such acts must be stopped at the outset to prevent miscarriage of justice.” [Para 24]

The Court further cited Ravinder Singh v. Sukhbir Singh, to hold that where allegations are vague, delayed, and unsupported by evidence, the High Court rightly exercises its inherent jurisdiction under Section 482 CrPC to prevent abuse of legal process.

“Prosecution needs to be quashed at an early stage to prevent undue harassment of the accused where the entire case is a bad faith exercise rather than a pursuit of justice.” [Para 23]

“No Independent Discretion or Mala Fide Intent is Alleged or Proved”: Supreme Court Finds No Justification to Overturn High Court's Quashing Order

The Appellant had argued that there were 39 witnesses and voluminous material to establish a prima facie case under Sections 3(1)(viii), 3(1)(ix), and 3(2)(vii) of the SC/ST Act. However, the Court found that these were bare allegations, unsupported by any substantive proof of caste-based humiliation or targeting.

“The very intent being absent, the offences for which the prosecution has been launched are not made out.” [Para 22]

The Bench added that the mere pendency of multiple litigations between the parties could not, by itself, justify criminal prosecution under the SC/ST Act without clear evidence of caste-based animus.

“Specific instances and incidents supported by evidence are required to be present, which is missing in this case.” [Para 22]

“High Court Did Not Overstep Its Jurisdiction Under Section 482 CrPC”: SC Upholds Use of Inherent Powers to Prevent Abuse of Process

The Supreme Court firmly rejected the Appellant’s contention that the High Court had prematurely evaluated evidence. It held that the High Court appropriately exercised its jurisdiction under Section 482 of CrPC to quash proceedings which, even on the face of the complaint, failed to disclose a legally sustainable offence.

“The observations and conclusions arrived at by the High Court are based upon the proper appreciation of the pleadings, the correct reading and application of law and thus, cannot be faulted with.” [Para 25]

The Supreme Court’s ruling in Konde Nageshwar Rao v. A. Srirama Chandra Murty underscores the delicate balance courts must maintain in protecting the rights of SC/ST individuals while guarding against abuse of protective statutes.

“The law must not be allowed to become an instrument of oppression through false implication and personal vendetta.”

By upholding the High Court’s decision to quash proceedings, the Court sent a strong message that allegations under the SC/ST Act must not only involve caste identity, but must also reveal intent to humiliate on that basis—a threshold not met in this case.

Date of Decision: July 23, 2025