Supreme Court Upholds Quashing of Case Under SC/ST Act: Finds No Mala Fide in Police Action: Bench of Justice B.R. Gavai and Justice A. G. Masih

In an influential judgement dated July 23, 2025, a bench of the Supreme Court of India dismissed a writ appeal overturning a High Court decision by which criminal proceedings had been quashed with an application alleging A crime under the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989 ( SC/ST Act ). The case, which followed the dispute over the land allotment and false implication in a criminal case, shows the critical importance of the prevention of the abuse of SC/ST Act as the vessel used to settle personal scores. In its verdict, the Supreme Court indicated that being a member of Scheduled Caste or a Scheduled Tribe is not a sufficient condition to be prosecuted under the Act; the atrocities must be with the sole purpose of hurting the victim because of his or her caste.

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Background of the Case

This court battle originated over a land distribution tiff in the village of Duvva. According to the appellant Konde Nageshwar Rao, the Mandal Revenue Officer (MRO) (Respondent No. 2) A. Srirama Chandra Murty in cahoots with Accused No. 3 (Proprietor of Ramakrishna Cine Theatre) had rigged the allotment of two plots. These were the plots, which had been marked, to be given away to SC/ST beneficiaries, but they were given away to the upper caste members, who bribed Accused No. 3 in exchange.

This allotment was objected by the appellant who stated that it was due to this allotment that he was wrongly implicated in a criminal case in an act of vindictiveness. This case of crime even led to suspension of the appellant, who was working as a Junior Accountant at the Government Printing Press, at Hyderabad. A probe conducted later on found that the appellant was not even there at the village where the crime that he was accused to be involved in took place. The case against him was criminal in nature and filed on a 15th May, 1995 serious clash between two groups of the Scheduled Castes at Kothamalapalli village.

A. Srirama Chandra Murty, (Sub-Inspector of Police, Investigating Officer in that case) (Respondent No.1, now deceased), did not, at the time of lodging the FIR, mention the name of the appellant, and only in the charge-sheet did the name of the appellant appear. The appellant claimed that the prosecution was based on his wrongful conspiracy but because of his Scheduled Caste and a malicious motive to invoke prosecution against him. Later on the Competent Authority produced a report that the appellant was innocent and criminal charges against the appellant were withdrawn.

After the case against him was withdrawn the appellant has levelled a complaint against the Respondent No. 1 and 2, and the Accused No. 3. He claimed that the Respondent No. 1 was incited by the Respondent No. 2 and the Accused No. 3 and this was how all the three formulated to involve him and his brother. There were allegations of humiliation, hounding and offence of SC/ST Act. These allegations were proved accordingly during one investigation which was done by a Deputy Superintendent of Police resulting in reaching up to a complaint after securing necessary sanction of prosecution.

These proceedings against the respondents were quashed by the High Court in a petition filed under Section 482 of the Code of Criminal Procedure (CrPC) result in this present appeal before the Supreme Court.

Arguments Presented

The counsel of the appellant argued that the High Court wrongly exercised its jurisdiction under Section 482 CrPC because overwhelming evidence had been provided to prove a strong case of prima facie under Section 3(1)(viii), 3(1)(ix) and 3(2) (vii) of SC/ST Act, that is 39 witnesses and material consisting of incriminating evidence. It was contended that the High Court had gone out of jurisdiction in probing into the prosecution case in a roving manner and formulating its opinion on the evidence at the pre-trial level, which should do the trial court.

The counsel on behalf of Respondent No. 2 (MRO) on the contrary, argued that they had no mala fide intention, being only acting in accordance with the government directions and in virtue of the directions of the superiors. They claimed that the claims were not true, driven and barred by time implying that the appellant had a mala fide motive to take revenge. There was a report of the Sub-Collector, Kovvur, which cited, that no mala fide intention was found on the part of the MRO since the plot allotments were done by government orders, according to which the departmental proceedings against him were dropped.

It was also mentioned that the arrest of the appellant was in accordance to the instructions of the Sub-Collector and SDM, Kovvur. The fact that the government dismissed the case against the appellant at an early phase did not imply that he was falsely accused because they had not endured the witness statements in a court of law. The fact that the complaint was filed long after the said incident (May 1995 and June 2003) was also noted which may be evidence of ill will. Moreover, the argument was that whereas provisions in SC/ST Act is supposed to have an element of malafides at the onset, which was lacking in the case. The conflict itself was clearly not fuelled by caste related malice but was actually between two Scheduled Castes; and the remedial measures taken by the MRO were not based on his own unfettered discretion or ridden with malaise but were clearly as directed by the higher ups.

Analysis and decision of the Supreme Court

The apex court, upon hearing the submissions and upon hearing the records was not disposed to entertain the appeal. The Court pointed out that the case that was brought against the private respondents was brought by the appellant and it was as a result of his complaints since his criminal case was dismissed. The mala fide and wrongful prosecution charges against the accused 3 (MRO), on the basis of the charges by the accuser (MRO) were as a result of the wrongful allotment of the plots reserved to the Scheduled Castes, by the MRO to the Kapu community which the accused no. 3 allegedly collaborated with the Sub-Inspector.

More importantly the Court noted that the complaint made at the first stage about allotment of the land was prima facie valid but when inquired and explained on a truer basis it was held that the allotment made by Respondent No. 2 was in accordance with the directions of the government. The alotment was also cancelled. Hence, the Court could not find any cause as to why the Respondent No. 2 would want to go out of the way to involve the appellant and his family maliciously.

Moreover, the Court went on to note that the conflict existed between two Scheduled Caste groups and not with any other caste and therefore chances of the appellant being involved on mala fide grounds since the appellant too is Scheduled Caste were negligible. There was no evidence, which would show mala fide intention or connivance on part of Respondent No. 2. According to the Court Bald allegations alone cannot stand.

The grievance leveled in the complaint was indeed not of false and malicious involvement in criminal proceedings based on the fact that the appellant was a Scheduled Caste and in that case, the person to which the act is committed did not have the necessary intent to constitute the latter offences under the SC/ST act as stated by the Supreme Court. The fact that several litigations were pending between the appellant and Respondent No. 2 could not be a basis to assuming false and malicious prosecution. To enable offenses under the Act, particular cases and experiences should be proved by evidence, which were not present in the case.

The Court made the same decision as before.

Masumsha Hasanasha Musalman v. State of Maharashtra and

Dr. Subhash Kashinath Mahajan and another v. State of Maharashtra together with another

saying that it is not possible to prosecute an individual based on the fact that he or she belongs to a Scheduled Caste or Tribe alone. The crimes should be perpetrated only on a basis of caste of the victim. The Court emphasised that misuse of the SC/ST Act should be curtailed and any prosecution of this nature should be killed at its initial stage where there is a visible legal flaw or in bad faith.

The Supreme Court held that the observations and conclusions made by the High Court were founded on a right understanding of the pleadings and a good reading of the law and application of law and, therefore, were not liable to any blame in case of impugned order. The appeal was thus thrown out. This decision reinforces the point on which we have discussed earlier that the SC/ST Act is indeed an important legislation that is required to safeguard the vulnerable communities, but it cannot be made through personal vendetta or when the pre-eminent aspect of caste-based atrocity is not involved.