INTRODUCTION
In Dr. Anand Rai v. State of Madhya Pradesh & Anr., 2026 INSC 141, decided on 10 February 2026, the Supreme Court of India, comprising Justice Sanjay Karol and Justice Nongmeikapam Kotiswar Singh, delivered an important Judgment clarifying the threshold required for framing charges under the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989.
The Court quashed the charges framed under Sections 3(2)(v) and 3(2)(va) of the SC/ST Act against the Appellant, holding that in the absence of prima facie material showing knowledge of the Victim’s caste or caste-based intent, continuation of proceedings under the Act would amount to mechanical application of a protective statute. The Judgment also reiterates the duty of Appellate Courts under Section 14-A of the SC/ST Act to independently scrutinize threshold orders.
BRIEF FACTS
The case arose from an incident dated 15 November 2022 during the unveiling of a statue of Bhagwan Birsa Munda in Ratlam, Madhya Pradesh. A large gathering allegedly obstructed the vehicles of public officials and engaged in altercations with police personnel. Injuries were reported and an FIR was registered.
Following investigation, a charge sheet was filed alleging offences under various provisions of the Indian Penal Code, including rioting, unlawful assembly, assault on public servants and causing grievous hurt. Charges under Sections 3(2)(v) and 3(2)(va) of the SC/ST Act were also invoked.
The Appellant sought discharge under Section 227 of the Code of Criminal Procedure, 1973. The Special Court partly allowed the Discharge Application but retained the charges under the SC/ST Act. The High Court, exercising appellate jurisdiction under Section 14-A of the SC/ST Act, dismissed the Appellant’s Appeal. Aggrieved, the Appellant approached the Supreme Court.
The sole issue before the Court was the sustainability of charges under the SC/ST Act.
ISSUES OF LAW
The principal question was whether, on the material placed on record, there existed sufficient prima facie evidence to attract Sections 3(2)(v) and 3(2)(va) of the SC/ST Act, particularly with respect to the element of knowledge that the victim belonged to a Scheduled Caste or Scheduled Tribe.
A related issue concerned the scope of appellate scrutiny under Section 14-A of the SC/ST Act when dealing with orders framing charge.
ANALYSIS OF THE JUDGMENT
The Supreme Court began by restating the object and constitutional foundation of the SC/ST Act. The statute is a transformative instrument intended to provide substantive equality and protection to historically oppressed communities. Its stringent provisions reflect the gravity of caste-based violence and discrimination. At the same time, the Court emphasized that its application must be grounded in the statutory ingredients prescribed by law.
Section 3(2)(v) requires that the accused commit an offence punishable with ten years or more under the IPC against a person or property belonging to a Scheduled Caste or Scheduled Tribe knowing the caste identity of the victim. Section 3(2)(va) similarly presupposes commission of a scheduled offence with awareness of the victim’s caste. Knowledge is therefore not incidental but foundational.
The Court examined the record and noted that neither the FIR nor the statements recorded under Section 161 CrPC contained any averment that casteist slurs were uttered or that the alleged acts were motivated by caste considerations. Even more significantly, there was no material suggesting that the Appellant possessed knowledge of the Complainant’s caste identity. The Trial Court itself had recorded that no specific caste-based abuses were attributed to the Accused, yet proceeded to frame charges under Sections 3(2)(v) and 3(2)(va).
In the absence of any material indicating caste awareness or caste-based targeting, the Court found it impossible to sustain even a prima facie inference under the SC/ST Act. The existence of allegations under the IPC could not automatically justify invocation of the special statute.
Turning to the scope of appellate jurisdiction under Section 14-A, the Court clarified that such an appeal is a statutory first appeal on facts and law. The High Court is obligated to independently assess whether the ingredients of the offence are prima facie made out. A mechanical affirmation of the Special Court’s Order without analyzing the statutory prerequisites amounts to failure to exercise jurisdiction.
The Court reiterated established jurisprudence on discharge and framing of charge, including principles from Sajjan Kumar v. CBI and Prafulla Kumar Samal, noting that while courts should not conduct a mini-trial at this stage, they must examine whether the basic ingredients of the offence are disclosed on the face of the record. Where even that threshold is not crossed, discharge is not a concession but a legal necessity.
The Bench concluded that the charges under the SC/ST Act lacked foundational material and therefore could not be sustained. The proceedings were remitted to the Trial Court to continue on the remaining IPC charges.
CONCLUSION
This Judgment draws a careful but firm doctrinal boundary. While reaffirming the constitutional significance and protective purpose of the SC/ST Act, the Supreme Court has clarified that its invocation cannot rest on assumption or inference unsupported by material on record. The element of knowledge regarding caste identity is not ornamental; it is essential.
The ruling also strengthens appellate discipline under Section 14-A by emphasizing that first appellate courts must independently examine whether statutory ingredients are prima facie satisfied.
Ultimately, the Court’s reasoning rests on a broader principle: criminal prosecution must not proceed where the statutory foundation is absent. Protective legislation must be applied with seriousness and sensitivity, but also with fidelity to its defined outlines. In quashing the SC/ST charges while allowing the IPC charges to proceed, the Court has preserved both the integrity of the statute and the fairness of the criminal process.
SARTHAK KALRA
Senior Legal Associate
The Indian Lawyer & Allied Services
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