Supreme Court Quashes Charges Under SC/ST Act Against Vyapam Whistleblower Dr Anand Rai

Background

The present matter arises from an incident that took place on November 15, 2022, at village Dharad in Ratlam district during a programme organised on the occasion of Birsa Munda Jayanti for the unveiling of a statue of Bhagwan Birsa Munda.

According to the prosecution, around 1:00 pm near a temple on Bhatibadodiya Road, members of the JAYS organisation, including Dr. Rai, intercepted and stopped the vehicles of a Member of Parliament, a Member of the Legislative Assembly, the Collector and other officials.

The FIR, registered on the complaint was lodged by one Vikas Pargi, alleged that the group blocked the road for nearly one hour, abused the MP and MLA, and engaged in a scuffle with police personnel who attempted to clear the way. The accused allegedly pelted stones at the official vehicles and the Collector's security guard other police personnel were also reported injured. Dr. Rai was named among approximately 40-45 persons identified in the FIR.

On March 18, 2025, the Special Sessions Judge (SC/ST Act), Ratlam framed charges against Dr. Rai under Sections 341 read with Section 149 of IPC, Section 147 IPC, Section 333 read with Section 149 IPC also read with Section 3(2)(va) of SC/ST (PA) Act, 1989; Section 326 read with Section 149 of IPC also read with Section 3(2)(va) of SC/ST (PA) Act; Section 332 read with section 149 (two counts) of IPC, Section 353 read with Section 149 IPC, Section 352 read with Section 149 of IPC, Section 427 read with Section 149 IPC, Section 323 read with Section 149 of IPC and Section 3(2)(v) of SC/ST (PA) Act.

Dr. Rai challenged the framing of charges before the Madhya Pradesh High Court arguing that the investigation was vitiated because it was conducted by an Inspector and not by an officer not below the rank of Deputy Superintendent of Police as required under Rule 7 of the SC/ST Rules, 1995. He further contended that there were no specific allegations of caste-based abuse or overt acts against him, and his presence at the spot was not conclusively established.

The State opposed the appeal and relied on witness statements which stated that Dr. Rai was part of the rally organised by JAYS and was present at the spot when the vehicles were stopped and the scuffle occurred.

On July 3, 2025, the Madhya Pradesh High Court dismissed the appeal. The High Court held that in view of Section 9 of the SC/ST Act and the State notification and circular, the offences registered in the FIR could be investigated by an Inspector.

On the issue of framing of charges, the High Court held that at the stage of framing of charge, the court is required to examine whether there is ground for presuming that the accused committed an offence, and a strong suspicion based on the material on record is sufficient. The High Court concluded that the trial court had not committed any error in framing charges against Dr. Rai.

The Supreme Court had earlier granted Dr. Rai bail in connection with the same case and subsequently stayed the trial proceedings under the SC/ST Act.

Challenging the High Court's decision to uphold the framing of charges, Rai filed the present appeal before the Supreme Court.

Case no. – SLP(Crl) No. 010711 - / 2025

Case Title – Dr. Anand Rai v. State of Madhya Pradesh