CASE NAME: Dr Anand Rai v. State of Madhya Pradesh and Anr.
CASE NUMBER: Criminal Appeal @ SLP (Crl.) No. 10711 of 2025
COURT: Supreme Court of India
DATE: 10 February 2026
QUORUM: Justice Sanjay Karol, Justice Nongmeikapam Kotiswar Singh
FACTS
The present case originates from the incidents that took place on 15 November 2022, when a large congregation of persons had gathered at Bachhadapara to witness the unveiling and installation of a statue of Birsa Munda. The complainant, Vikas, witnessed members of JAYS Organisation intercept the vehicles of the members of Parliament and Legislative Assembly, along with other district officials, arriving at the event. When they were being removed by the security, a scuffle occurred, and stone pelting started. One security personnel, namely Sandeep Chandel, suffered injuries as a result of the incident. The complainant allegedly videotaped the incident and submitted it to the police. Interrogations began, and the accused persons were taken into custody. Among them, the present accused’s vehicle, allegedly used in the incident, was also seized. The accused sought bail, which was rejected by the Trial Court and by the High Court, but the Supreme Court granted bail on 13 January 2023.
ISSUES
- Whether the charges under the SC/ST Act against the appellant are sustainable.
- Whether the investigation conducted by the Inspector rather than the DSP was lawful.
- Whether the High Court, exercising first-appeal jurisdiction, properly performed independent scrutiny when it affirmed the Trial Court’s order framing charges.
LEGAL PROVISIONS
- Sections 294, 341, 383, 332, 146, 147, 149, 336, 353, 326, 506, 333, 188 and 326 of the Indian Penal Code, 1860.
- Sections 3(1)(r), 3(2)(va), 14A of the SC/ST Act, as amended in 2015 and 2018.
ARGUMENTS
APPELLANT:
The counsel on behalf of the Appellant contended that the charges levied upon the appellant should be discharged since the FIR and statements recorded do not aver any caste-specific slur or any fact establishing that the complainant was a member of the SC or ST community. They contended that the essential ingredient of knowledge of the victim’s caste was missing, hence the evidence to invoke the legislation was absent. Further, they contended that no specific casteist words were recorded; the allegations were not sufficient to conclude that the assault was caste-motivated. They contended that the High Court failed to perform its duty as the first appellate court under Section 14A to independently examine the record with respect to the charges.
RESPONDENTS:
The counsel on behalf of the Respondent contended that multiple witness statements, the injured security personnel, the seized vehicle, and the video show the presence of the appellant and his participation in the assembly that committed the offences. They stated that the IPC and SC/ST Act provisions are attached, where offences in prosecution of a common object are shown. In such cases, specific overt acts per accused need not be proved at the threshold. Further, they contended that the investigation by the Inspector was lawful as per the State notification permitting such an officer to investigate specified offences.
ANALYSIS
The Hon’ble Court observed that the State rules and notifications empower officers below the rank of the DSP to investigate specified offences. Hence, the investigation conducted by an Inspector shall therefore be lawful. The Court further restated established principles that at the time of framing, the judge must see whether material, taken at face value, discloses ingredients of the offence and gives rise to a strong suspicion. They stated that the court must avoid a mini-trial but may sift evidence to the limited extent needed to form a prima facie view. The Court accepted that membership of an unlawful assembly and the possibility of a shared common object need only to be indicated prima facie. They stated that specific overt acts need not be attributed to each accused at the framing stage.
They observed that the SC/ST Act aims to provide targeted legal protection embodying the principles enshrined in Article 14, Article 15, Article 17, Article 21, Article 38 and Article 46. It was observed that for a charge under the concerned provision of the SC/ST Act to be established, the accused must first commit an offence under the IPC, such as assault, robbery, or any other crime punishable with ten or more years of imprisonment, the act must be directed against a member of a Scheduled Caste or Scheduled Tribe, or against their property and the accused must have knowledge that the victim belongs to a Scheduled Caste or Scheduled Tribe. With regard to this, the Trial Court noted that the absence of any explicit allegation or material establishing the complainant’s caste or that the accused acted knowing the caste, and held that the necessary element of knowledge was not made out even prima facie. The Hon’ble Supreme Court further observed that the High Court, being the first appellate court, ought to have independently examined the record as to whether the statutory ingredients of the SC/ST offences were even prima facie disclosed. Their failure in doing so results in a loss of judicial responsibility.
JUDGMENT
The Hon’ble Court held that the charges against the accused with regard to the SC/ST Act stand quashed and the matter is remitted back to the Trial Court to proceed in accordance with law regarding the other charges framed against the accused. The present Criminal Appeal was allowed.
CONCLUSION
To conclude, the present case highlights the delicate balance between protecting members of the Scheduled Castes and the Scheduled Tribes from targeted violence and ensuring that criminal prosecutions are grounded in clearly established statutory ingredients. The Supreme Court emphasised that mere participation in an alleged offence is insufficient to attract the special statute unless there is prima facie material demonstrating both the victim’s caste status and the accused’s knowledge thereof.
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WRITTEN BY: STUTI ANVI
