The bench observed that at the stage of framing of charge, the Court is only required to examine whether a prima facie case exists and not to conduct a “mini-trial”.

A bench of Justice Santosh Rai thus dismissed the criminal appeal filed by Chandra Prakash Singh alias Goli Thakur, who had challenged the trial court's order rejecting his discharge application in a case registered under Section 352 BNS, Section 66 IT Act and Section 3(1)(Dha) SC-ST Act.

Before the High Court, the appellant argued that the FIR was lodged with an unexplained delay of about seven days and no specific casteist words have been mentioned therein.

It was further contended that the allegations are vague and the essential ingredients of the offence under Section 3(1)Dha of the SC/ST Act are not made out

The State, on the other hand, opposed the appeal, submitting that the appellant was specifically named in the FIR and the investigation has collected sufficient prima facie material, including the Facebook post containing the objectionable statements.

It further argued that prosecution witnesses had supported the allegations and that, at the stage of framing charges, the court is only required to determine whether a prima facie case exists and not undertake a detailed evaluation of the evidence.

Considering the case record, the High Court noted that although the FIR did not reproduce the specific casteist words allegedly used, it did allege that abusive remarks had been made against MP Chandrashekhar Azad.

The Court further noted that during investigation, the Investigating Officer collected the Facebook post containing the alleged objectionable statements and placed the relevant material on record.

It also observed that the statements of prosecution witnesses specifically mentioned the abusive words allegedly used and supported the prosecution case.

In view of this, the bench noted that a prima facie perusal of the material indicated that the impugned remarks were allegedly directed against a particular community belonging to the Scheduled Castes/Scheduled Tribes

Rejecting the appellant's appeal, the Court observed:

"At the stage of summoning or framing of charge, the Court is only required to examine whether a prima facie case is made out and is not expected to conduct a mini-trial or meticulously appreciate the evidence".

The Court further referred to the Supreme Court's decisions in Sheoraj Singh Ahlawat v. State of Uttar Pradesh 2012, Rajbir Singh v. State of U.P. 2006, and Ghulam Hassan Beigh v. Mohammad Maqbool Magrey, which reiterate that while considering discharge or framing of charge, courts may sift the prosecution material only to ascertain whether a prima facie case or grave suspicion exists, but cannot weigh the evidence as if conducting the trial itself.

Holding that the trial court had rightly rejected the discharge application and that its order suffered from no illegality, perversity or infirmity, the High Court dismissed the appeal.