Camouflaged Disputes: Andhra Pradesh High Court Nixes SC/ST FIR Over Lack of 'Public View'

In a significant ruling aimed at preventing the weaponization of sensitive penal provisions, the High Court of Andhra Pradesh at Amaravati has quashed criminal proceedings initiated under the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989. Justice Dr. Y. Lakshmana Rao, presiding over the bench, held that private monetary disputes cannot be transparently rebranded as caste-based atrocities, especially when essential statutory elements—such as acts occurring within "public view"—are conspicuously absent.

The Backdrop: Alibi vs. Allegation The case involved petitioner Pasupuleti Chinachennaiah, who was accused of borrowing money and subsequently hurling caste-based insults while refusing repayment. The complainant further alleged that a second accused visited her residence to seize documents and continue the verbal abuse. Consequently, an FIR under Section 79 of the Bharatiya Nyaya Sanhita (BNS)—the successor to Section 509 IPC—and Sections 3(1)(r), 3(1)(s), and 3(2)(va) of the SC/ST (POA) Act was registered.

The petitioner adamantly denied these charges, presenting a plea of alibi, noting that he was employed in Melbourne, Australia, at the time of the alleged incident. He argued that the entire prosecution case was a "colorable exercise" designed to coerce him into settling a civil monetary dispute through criminal intimidation.

The Judicial Scrutiny During deliberations, the High Court scrutinized the foundation of the allegations. The core issue was whether the insults—assuming they occurred—satisfied the strict requirements of the SC/ST Act. The Court leaned heavily on the precedents set in Hitesh Verma v. State of Uttarakhand and B. Venkateswaran v. P. Bakthavatchalam , which delineate that private, non-public disagreements fall outside the scope of the Act.

Justice Rao noted that the FIR and subsequent charge sheet lacked any evidence that the alleged incident occurred in " public view " or in the presence of independent witnesses, characterizing the complainant's accusations as "omnibus and bereft of particulars."

Key Observations The High Court’s order emphasized that the integrity of the SC/ST (POA) Act must be preserved for genuine cases of systemic oppression, rather than used as a mechanism for personal vendetta:

  • "Private monetary disputes camouflaged as caste‑based offences, absent the foundational ingredients of intentional humiliation in public view , amount to a colourable exercise of criminal law and constitute an abuse of process ."
  • "The complaint herein was conspicuously bereft of any averment anent public presence or independent witnesses, rendering the alleged caste-based slurs a purely private altercation."
  • "The endeavour to transmogrify such quintessentially civil obligations into criminal atrocities... bespoke a colourable exercise of process."
  • "The prosecution's edifice rests upon omnibus allegations of caste‑based abuse and monetary transactions, which, even if taken at their highest, fail to disclose the indispensable statutory ingredients."

Conclusion and Impact Concluding that the investigation was "perfunctory" and had failed to even verify the petitioner’s claims of being abroad, the Court stated that allowing the trial to continue would result in a miscarriage of justice.

The decision serves as a stern reminder to law enforcement and investigating agencies to ensure that prima facie ingredients are met before pressing charges under the SC/ST Act. By quashing the proceedings in S.C. No. 165 of 2025 , the Andhra Pradesh High Court has reinforced the principle that the judiciary will intervene when criminal statutes are stretched to address private, civil-natured grievances.