Key information
Summary
The appellant approached the Supreme Court seeking the quashing of criminal proceedings
initiated against him under the Scheduled Castes and Scheduled Tribes (Prevention of
Atrocities) Act. The prosecution alleged that casteist remarks were made during a private
dispute inside an enclosed office space where no independent members of the public were
present. The High Court had declined to quash the charges, prompting a constitutional appeal.
Analyzing the statutory ingredients alongside Article 21 (Right to Dignified Life) and strict
principles of criminal interpretation, the Supreme Court examined whether private utterances
meet the essential requirement of occurring within “public view”. The Bench emphasized that
the statutory intent of the SC/ST Act is to penalize public humilation and systemic atrocity,
rather than converting every private interpersonal conflict into a specialized non-bailable
offence without public exposure.
Quashing the charges under the SC/ST Act, the apex court held that caste-based insults
uttered within private or enclosed premises without the presence of independent public
witnesses do not constitute an offence under the Act. The Court clarified that while such acts
might attract general penal provisions if criminal intimidation is proven, invocation of the
Atrocities Act requires clear proof that the place was accessible or visible to the general
public.
