The Supreme Court on Thursday (20.08.2026) quashed proceedings under Sections 3(2)(r) and 3(1)(s) of the Scheduled Castes and the Scheduled Tribes (Prevention of Atrocities) Act. 1989 (SC/ST Act). The case was filed against a school manager, accusing him of assaulting and hurling caste-based abuses at the father of two students. The Supreme Court quashed the case, holding that the alleged utterances were made inside an enclosed room with no public access, and therefore did not satisfy the essential statutory requirement.

A bench of Justice Vikram Nath and Justice Sandeep Mehta ruled so while hearing an appeal against a judgment passed by the Allahabad High Court, which had dismissed the appellant's appeal under Section 14A(1) of the SC/ST Act.

The appellant was the Manager of the school where the respondent's (R2) sons studied. Following a quarrel between two students, R2 approached the appellant, who allegedly abused and assaulted him along with the school-staff, and used caste-based abuses against him. An FIR under Sections 147, 323, 342, and 504 of the Indian Penal Code, 1860 (IPC, now , Sections 191, 115, and 352 of the Bharatiya Nyaya Sanhita, 2023) and Sections 3(1)(r) and 3(1)(s) of the SC/ST Act, was lodged against the appellant. A chargesheet was filed against him and the Special Judge took cognisance.

It is to be noted that a cross-FIR was also lodged the same day by the appellant's wife against R2, alleging that he had abused and assaulted her in the school office, following which the appellant intervened and was himself assaulted. A chargesheet was filed against R2 and cognisance was taken.

The appellant challenged the Special Judge's summoning order before the Allahabad High Court, which rejected his plea, holding that merely that the present case was a counterblast could not, by itself, be a ground for quashing and that a prima facie case was made out on material available. Aggrieved by the High Court's finding, the appellant approached the Supreme Court.

Before the Supreme Court, the appellant contended that the High Court had erred in holding that the incident occurred within public view. It was submitted that the witness statements did not establish that anyone was present inside the room at the time of incident, and that the room was enclosed and had no window or public access. It was also submitted that the FIR itself contained no specific allegation attributing caste-based abuses to the appellant, and that he had no prior knowledge of his caste.

On the contrary, the respondent relied on the High Court's judgment to contend that the incident occurred within public view and that there was sufficient material on record to establish such a case.

Perusing Sections 3(1)(r) and 3(1)(s) of the SC/ST Act, the Supreme Court noted that the core question was whether the material on record disclosed that the alleged caste-based abuses were uttered at a place within public view. Relying on its decision in Karuppudayar v State (represented by the Deputy Superintendent of Police, Lalgudi, Trichy) & Ors and Hitesh Verma v State of Uttarakhand, the bench reiterated, “it could thus be seen that, to be a place 'within public view', the place should be open where the members of the public can witness or hear the utterance made by the accused to the victim. If the alleged offence takes place within the four corners of the wall where members of the public are not present, then it cannot be said that it has taken place at a place within public view.”

Applying this, the Court observed that the FIR did not state that the alleged abuses were uttered in the presence or hearing of members of the public. It also noted the absence of any specific allegation of caste-based abuse neither in the FIR nor in R2's statements. “The material relied upon by the prosecution, at the highest, discloses a quarrel and scuffle between the parties. It does not disclose any specific caste-based utterance attributable to the appellant,” the bench observed.

Examining the statements of witnesses (school teachers), the Court observed that while they described an “altercation and scuffle”, none of them stated that they were present when the alleged caste-based abuses were uttered or they heard any of them. “Their mere presence in the school premises, therefore, does not establish that the alleged utterance was made within public view,” it was held.

The bench clarified that while the Court is not required to conduct a meticulous appreciation of evidence at the stage of cognisance, “the basic ingredients of the offence must emerge from the material placed before the Court.”

Holding that the offences under the SC/ST Act were not prima facie made out, the Supreme Court set aside the High Court's judgment and quashed the proceedings under the Act. The Court, however, clarified that the proceedings in respect of offences under the IPC would continue.

Case : Ramkrishna Chauhan v State of Uttar Pradesh & Anr

Citation : 2026 LiveLaw (SC) 837

Appearance:

For Appellant: Mr. Siddharth Aggarwal, Adv.

For Respondent: Ms Anushree Prashit Kapadia, Adv.

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