Mere Caste Identity Not Enough to Prove Atrocity: Supreme Court Acquits Two in SC/ST Act Case, Slams “Perverse” High Court Inference

"A finding that the offence was committed simply because the complainant belonged to a Scheduled Caste is perverse in the absence of any such evidence", Supreme Court of India delivered a pivotal ruling in Dadu @ Ankush & Anr. vs. State of Madhya Pradesh & Anr., sharply criticising the evidentiary approach adopted by the High Court in a criminal case involving alleged assault and outraging of modesty under the IPC and the SC/ST Act. The Bench comprising Justice Dipankar Datta and Justice Augustine George Masih found the conviction of the appellants "unsustainable," and concluded that the prosecution had failed to prove its case beyond reasonable doubt.

The Court set aside the concurrent findings of the Special Court and the Madhya Pradesh High Court, which had convicted the appellants under Sections 323 and 354 of the IPC and Section 3(1)(xi) of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989. Emphasising the need for careful scrutiny of evidence in cases involving serious allegations, the Court observed, “We do not see reason to hold, in view of the evidence of PW-5 and our above findings, that A-2 ought to be held guilty of an offence under Section 323 IPC.”

"THE HIGH COURT'S CONCLUSION WAS ABRUPT, UNSUPPORTED, AND LEGALLY UNSOUND"

The case revolved around a complaint filed by a young girl belonging to a Scheduled Caste who alleged that the accused had entered her home during a local Ganesh festival, harassed her, and assaulted her brother. The FIR specifically stated that A-2 "despite knowing that I belong to Schedule Caste... teased me, beaten and abused my brother." The Trial Court convicted both accused and the High Court affirmed the sentence, relying heavily on the caste identity of the complainant to uphold the charge under Section 3(1)(xi) of the SC/ST Act.

The Supreme Court, however, firmly rejected such reasoning. The bench observed, “There appears to be no statement in court in course of trial by the victim that A-2 committed the alleged offence only because of the victim being a member of Scheduled Caste. No such statement was even made by PW-2. The finding returned by the High Court is, thus, perverse.”

The Court clarified that to sustain a conviction under the SC/ST Act, there must be direct or inferable evidence that the offence was motivated by the victim’s caste. The mere fact that the victim belonged to a Scheduled Caste does not automatically satisfy the ingredients of Section 3(1)(xi).

"EVIDENCE OF A HOSTILE WITNESS CANNOT BE REJECTED OUTRIGHT; IT MUST BE CAREFULLY EXAMINED"

A key turning point in the case came from the testimony of PW-4, a relative of the complainant, who offered an entirely different version of events. He deposed that the incident had occurred at a crowded Ganesh pandal and stemmed from a scuffle after someone's foot was stepped on, contradicting the narrative that the victim was attacked inside her home.

The High Court had brushed aside his testimony merely because he was declared hostile. The Supreme Court rebuked this approach, stating, “The mere rejection of the evidence of PW-4 in the manner aforesaid is contrary to the law laid down by this Court.” Referring to State of U.P. v. Ramesh Prasad Misra (1996) 10 SCC 360, the Bench held that evidence of a hostile witness must not be discarded if it aids either the prosecution or the defence, but must be scrutinised carefully.

The testimony of PW-4 was held to support the defence version — that a scuffle broke out during the festival, leading to minor injuries, which were then exaggerated into a case of molestation and caste-based atrocity.

"GLARING DISCREPANCIES IN OCULAR AND MEDICAL EVIDENCE CAST SERIOUS DOUBT ON PROSECUTION CASE"

The medical evidence presented by PW-5 further weakened the prosecution's case. Though the complainant and her brother alleged specific injuries — bleeding from the nose and mouth, nail scratches on the back — none of these were confirmed in the medical examination conducted the next day. Instead, only minor scratch marks were recorded.

PW-5 confirmed during cross-examination that such injuries could have been caused by falling or being dragged on the ground. The Court remarked, “The injuries which were suffered by both the victim and PW-2 could have been possible if someone falls or gets dragged on the ground.”

Adding to the inconsistencies, the victim stated she screamed during the incident, but her brother testified that he returned home after being informed about a fight, not because he heard her scream. “If the statement of the victim is contrasted with the statement of PW-2, we find it improbable that victim’s loud screams could only reach the ears of PW-2 and no one else’s,” the Court noted.

"NO INDEPENDENT WITNESSES PRODUCED DESPITE CLAIM THAT 'MANY PEOPLE SAW THE INCIDENT'"

One of the most serious gaps in the prosecution case, according to the Court, was the failure to produce any independent eyewitnesses. PW-2 had claimed that many people from the locality saw the incident, yet not a single such witness was examined. The Court found this deeply suspicious, stating, “It would appear strange that none from the locality was produced in the court as a prosecution witness.”

The Court added that if the incident had occurred as claimed — in a public setting, during a community festival — it was unnatural that no bystanders came to help or were later examined in court. This absence of corroboration significantly weakened the credibility of the prosecution witnesses, especially given their familial relationship with the complainant.

"PROSECUTION FAILED TO PROVE GUILT BEYOND REASONABLE DOUBT; CONVICTION SET ASIDE"

The Court ultimately concluded that the inconsistencies in testimonies, lack of independent witnesses, and absence of corroborating medical evidence fatally undermined the prosecution case. The defence’s version — that there had been a scuffle at the pandal — was found to be more probable and credible.

Summarising its decision, the Court declared: “The conviction and sentence of the appellants being indefensible, stand set aside. They are set free and discharged from their bail bonds.”

This judgment reinforces the principle that accusations under special criminal laws like the SC/ST Act must be supported by clear evidence of motive and intent. It underscores that courts must resist the temptation to fill evidentiary gaps with presumptions based on the social identity of the parties involved.

Date of Decision: December 8, 2025

Case Title: Dadu @ Ankush & Anr. vs. State of Madhya Pradesh & Anr.