High Court Must Independently Apply Its Mind On SC/ST Act Charges In Appeal Under Section 14A : Supreme Court

The Supreme Court has criticized the Madhya Pradesh High Court's handling of a case under the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities Act)( SC/ST Act), noting that despite the absence of the basic ingredients of the offence being met, i.e., intentional caste-based insult or intimidation, the High Court proceeded with the criminal proceedings.

The Supreme Court held that while exercising appellate jurisdiction under Section 14A of the SC/ST Act, a High Court does not sit as a revisional or supervisory court but functions as a first appellate court. A mechanical affirmation of a Special Court's order, without independent scrutiny of the material on record, would amount to a failure to exercise jurisdiction, the Court said.

A Bench of Justices Sanjay Karol and N. Kotiswar Singh was hearing an appeal that arose from a November 15, 2022 incident during the unveiling of a statue of Bhagwan Birsa Munda at Bachhadapara in Madhya Pradesh. According to the prosecution, a large group allegedly associated with the JAYS organisation intercepted officials, pelted stones at vehicles, and assaulted personnel, resulting in injuries to a security official. Appellant-Dr. Rai was named as one of the accused.

The Trial Court had partly allowed the Appellant's discharge application. While it dropped certain charges, it retained charges under Sections 147, 341, 427, 353, 332, 333, 326, 352 and 323 read with Section 149 of the IPC, along with Sections 3(2)(v) and 3(2)(va) of the SC/ST Act.

The Madhya Pradesh High Court dismissed his statutory appeal under Section 14-A of the SC/ST Act, prompting the appellant to approach the Supreme Court.

Before the Supreme Court, the sole issue was the sustainability of the charges under the SC/ST Act.

High Court's Role Under Section 14A

The Court underscored that an appeal under Section 14A of the SC/ST Act is a statutory first appeal, both on facts and law. Even if the appellate court ultimately agrees with the Special Court, its judgment must reflect that it independently examined the material and applied its mind.

"The High Court does not function as a revisional or supervisory Court while exercising jurisdiction under Section 14-A but assumes the role of a first appellate court. A mechanical affirmation of the order of the Special Court, without independent scrutiny, would therefore be inconsistent with settled appellate jurisprudence and would amount to a failure to exercise jurisdiction. Even where the appellate Court ultimately agrees with the reasoning of the Courts below, the judgment must disclose that the material was independently examined."

At the same time, the Bench clarified that the width of appellate power depends on the stage of proceedings. While appeals against conviction or acquittal permit comprehensive reappreciation of evidence, a different discipline applies at the stage of discharge or framing of charge.

Relying on settled precedents including State of Bihar v. Ramesh Singh and Union of India v. Prafulla Kumar Samal, the Court reiterated that at the threshold stage, the test is whether the material, taken at face value, discloses the essential ingredients of the alleged offence and raises grave suspicion. Courts are cautioned against conducting a roving inquiry or weighing evidence as if at trial.

Thus, while hearing an appeal against an order framing charges under the SC/ST Act, the High Court must examine whether the basic statutory ingredients are prima facie made out. If those foundational elements are absent, interference is justified. However, the appellate court cannot adjudicate disputed facts or evaluate witness credibility at this stage.

"Thus, the appellate power under Section 14-A of the SC/ST Act must be exercised in harmony with the broader framework of criminal procedure. While the High Court is duty- bound, as a first appellate Court, to independently apply its mind and correct errors committed by the Special Court, it must remain conscious of the stage of the proceedings and the corresponding limits of judicial scrutiny. This calibrated approach ensures that the protective object of the SC/ST Act is preserved, while simultaneously safeguarding against mechanical application of its provisions in cases where the statutory ingredients are not even prima facie disclosed."

Quashing charges framed under the SC/ST Act, the Court said that when an statutory appeal is filed against the framing of charges, it is not incumbent upon the High Court to do a roving enquiry into the allegations, rather their role is limited to ascertaining whether the allegations disclose the basic statutory ingredients of the offence under the Act, i.e., whether the alleged act was committed on account of the victim's caste and whether other foundational requirements are satisfied.

“…the test is whether the material on record, taken at face value, discloses the essential ingredients of the alleged offence and gives rise to a strong or grave suspicion against the accused. The Court is expressly cautioned against conducting a roving inquiry or weighing the evidence as if at trial. When these generally applicable principles are applied to an appeal under Section 14-A of the SC/ST Act arising from a threshold order, the High Court's role, though appellate in nature, stands circumscribed by the limits governing discharge. The High Court may examine whether the allegations disclose the basic statutory ingredients of the offence under the Act, including whether the alleged act was committed on account of the victim's caste and whether other foundational requirements are satisfied. Where these ingredients are conspicuously absent, interference is justified, as continuation of proceedings would amount to an abuse of the process of law. This form of scrutiny does not amount to appreciation of the material but is an exercise in legal evaluation of the allegations as they stand.”, the judgment authored by Justice Karol said.

The Court observed that when there was no allegation of casteist language and no specific averment in the record that the complainant belonged to an SC/ST community, there was no basis to infer that the alleged acts were informed by caste-based knowledge or intent.

Also, the Court discussed the Trial Court's role, as a court of first instance, not to proceed in cases that disclose no prima facie ingredients to justify continuation of the criminal proceedings. Since the essential ingredients of the charges levelled against the appellant were absent, the court said that the charges could not be sustained.

“we are at a loss to understand that when the Trial Court itself acknowledges that none of the statements under Section 161 CrPC, state the specific slurs uttered by the accused with the intent to insult threaten or kill, then how is it found, on the same bundle of evidence, and with the same level of scrutiny thereof, that the alleged acts of the accused were informed by caste awareness. There does not appear to be any other material on record either, to establish knowledge on part of the accused. Once the knowledge on part of the alleged offender is in question, it is but certain that the charge cannot stand.”, the court said.

“To allow a matter to proceed despite the absence of a prima facie case is to expose a person to the strain, stigma, and uncertainty of criminal proceedings without legal necessity. Fidelity to the rule of law requires the Court to remember that the process itself can become the punishment if this responsibility is not exercised with care…For a litigant or an accused, the Trial Court is not just one level in a hierarchy. It represents the face of the judiciary itself. The sensitivity, fairness, and legal discipline shown at this stage shape how ordinary citizens understand justice. The impression a Trial Court creates, through its approach to facts and law, often becomes the impression people carry of the entire judicial system. That is why, at every stage and especially at the threshold, Trial Courts must remain alive to the human consequences of their decisions and to the trust that society places in them.”, the court observed.

Accordingly, the appeal was allowed to the extent that the charges against the accused, so far as the SCST Act stands quashed. The matter is remitted back to the Trial Court to proceed in accordance with the law regarding the other charges framed against the accused.

Cause Title: DR. ANAND RAI VERSUS STATE OF MADHYA PRADESH & ANR.

Citation : 2026 LiveLaw (SC) 136

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Appearance:

For Petitioner(s) :Mr. Kapil Sibal, Sr. Adv. Mr. Sumeer Sodhi, AOR Mr. Varun Tankha, Adv. Mr. Harshit Bari, Adv. Mr. Inder Dev Singh, Adv. Mr. Vipul Tiwari, Adv. Ms. Divyani Deepti, Adv. Ms. Divya Goyal, Adv. Mr. Chaitanya Sharma, Adv.

For Respondent(s) :Mr. Pashupathi Nath Razdan, AOR Mr. Kushagra Singh, Adv. Ms. Maitreyee Jagat Joshi, Adv. Mr. Astik Gupta, Adv. Ms. Akanksha Tomar, Adv.