Judicial Analysis Court Copy Headnote Facts Arguments Court observation

2026 Supreme(SC) 153

SUPREME COURT OF INDIA
SANJAY KAROL, NONGMEIKAPAM KOTISWAR SINGH, JJ.
Dr. Anand Rai – Appellant
Versus
State of Madhya Pradesh and Another – Respondents
Criminal Appeal No. 814 of 2026 [Arising Out of SLP (Crl.) No. 10711 of 2025]
Decided On : 10-02-2026

Advocates appeared:
For the Petitioner(s): Mr. Sumeer Sodhi, AOR Mr. Varun Tankha, Adv. Mr. Harshit Bari, Adv. Mr. Inder Dev Singh, Adv. Mr. Vipul Tiwari, Adv. Ms. Divyani Deepti, Adv. Ms. Divya Goyal, Adv. Mr. Chaitanya Sharma, Adv.
For the Respondent(s): Mr. Pashupathi Nath Razdan, AOR Mr. Abhinav Srivastav, Adv. Ms. Maitreyee Jagat Joshi, Adv. Mr. Astik Gupta, Adv. Ms. Akanksha Tomar, Adv.

IMPORTANT POINTS
(1) SC/ST Act is a transformative instrument, bridging gap between constitutional ideals and everyday realities, ensuring that SC/ST citizens can live as equal, dignified, and empowered members of society – For a charge under provisions of SC/ST Act to be established, several elements must be present – Offender must know caste identity of victim or that property belongs to them, ensuring that law applies to deliberate acts of caste-based harm.
(2) Appellate power under Section 14-A of SC/ST Act must be exercised in harmony with broader framework of criminal procedure – Calibrated approach ensures that protective object of SC/ST Act is preserved, while simultaneously safeguarding against mechanical application of its provisions in cases where statutory ingredients are not even prima facie disclosed.
(3) Discharge of accused – At stage of framing of charge or considering discharge, Court is not dealing with an abstract legal exercise – Power to frame a charge is not meant to be exercised by default or out of caution alone.

Headnote:
(A) Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989 – Sections 3(2)(v), 3(2)(va) – Indian Penal Code, 1860 – Sections 147, 341, 427, 353, 332, 333, 326, 323, 352 read with 149 – Criminal Procedure Code, 1973 – Sections 227 and 228 – Attack on Peoples’ Representatives, District Officials and Security Personnel – Framing of charge – SC/ST Act is a transformative instrument, bridging gap between constitutional ideals and everyday realities, ensuring that SC/ST citizens can live as equal, dignified, and empowered members of society – For a charge under provisions of SC/ST Act to be established, several elements must be present – Offender must know caste identity of victim or that property belongs to them, ensuring that law applies to deliberate acts of caste-based harm – At the stage of discharge, Court is required to consider whether there is any sufficient ground for proceeding against accused in sessions cases, or whether charge is groundless in Magistrate warrant cases – Established jurisprudence developed under Cr.P.C. on scope and limits of consideration at stages of discharge and framing of charge continues to hold field under BNSS – Statutory language supports the conclusion that Legislature has retained same substantive balance between rights of accused and interest of prosecution, while seeking to impose greater procedural discipline and expedition. (Paras 9, 10 and 11)
(B) Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989 – Section 14-A – Indian Penal Code, 1860 – Sections 147, 341, 427, 353, 332, 333, 326, 323, 352 read with 149 – Criminal Procedure Code, 1973 – Sections 227 and 228 – Attack on Peoples’ Representatives, District Officials and Security Personnel – Framing of charge – Only for reason that on a facial analysis of evidence placed on record, some of charges of IPC, appear to be met, SC/ST Sections have also been charged against accused – There is no averment that complainant was a member of SC/ST Community – High Court in deciding appeal against partial order of discharge, has not carried out its duty as first court of appeal – Impugned judgment/order of High Court, although running into eighteen pages, does not deal at all with charge under SC/ST Act – First appellate Court in criminal matters is a Court of both fact and law and is obliged to independently evaluate material on record before either affirming or reversing findings of Courts below – Appellate Court has full power to reappreciate, reconsider, and review evidence upon which order of lower court is founded and to arrive at its own conclusions – This principle applies with equal force to appeals under Section 14-A of SC/ST Act – The provision does not curtail or dilute ordinary appellate powers of High Court – High Court does not function as a revisional or supervisory Court while exercising jurisdiction under Section 14-A but assumes role of a first appellate court – Mechanical affirmation of order of Special Court, without independent scrutiny, would be inconsistent with settled appellate jurisprudence and would amount to failure to exercise jurisdiction. (Paras 15, 16, 17 and 18)
(C) Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989 – Section 14-A – Indian Penal Code, 1860 – Sections 147, 341, 427, 353, 332, 333, 326, 323, 352 read with 149 – Appeal – Appellate power under Section 14-A of SC/ST Act must be exercised in harmony with broader framework of criminal procedure – While High Court is duty bound, as a first appellate Court, to independently apply its mind and correct errors committed by Special Court, it must remain conscious of stage of proceedings and corresponding limits of judicial scrutiny – This calibrated approach ensures that protective object of SC/ST Act is preserved, while simultaneously safeguarding against mechanical application of its provisions in cases where statutory ingredients are not even prima facie disclosed – Charges upon accused in so far as SCST Act stand quashed and matter remitted back to Trial Court to proceed in accordance with law regarding other changes framed against accused. (Paras 19 and 20)
(D) Criminal Procedure Code, 1973 – Section 227 – Discharge of accused – At stage of framing of charge or considering discharge, Court is not dealing with an abstract legal exercise – It is dealing with real people, real anxieties, and real weight of criminal prosecution – Judicial responsibility at this stage calls for care, balance, and honest engagement with facts on record – Power to frame a charge is not meant to be exercised by default or out of caution alone – When material placed before Court, taken at face value, does not disclose ingredients of an offence, law expects Court to have clarity and courage to say so and to keep such a case aside – Discharge is not a technical indulgence but an essential safeguard – Court must consciously distinguish between a genuine case that warrants a trial and one that rests only on suspicion or assumption or for that matter without any basis – To allow a matter to proceed despite absence of a prima facie case is to expose a person to strain, stigma, and uncertainty of criminal proceedings without legal necessity – Fidelity to rule of law requires Court to remember that process itself can become the punishment if this responsibility is not exercised with care. (Para 21)
Facts of the case:
In terms of impugned judgment, High Court dismissed accused’s appeal arising out of proceedings before Special Judge, Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989 whereby his prayer for discharge under Section 2273 of Code of Criminal Procedure, 1973, was allowed only in part.
Findings of Court:
For a litigant or an accused, the Trial Court is not just one level in a hierarchy. It represents face of the judiciary itself. The sensitivity, fairness, and legal discipline shown at this stage shape how ordinary citizens understand justice. The impression a Trial Court creates, through its approach to facts and law, often becomes the impression people carry of the entire judicial system. That is why, at every stage and especially at the threshold, Trial Courts must remain alive to the human consequences of their decisions and to the trust that society places in them.
Result : Criminal Appeal allowed.

Judgement Key Points

The facts of this case revolve around an incident that occurred on November 15, 2022, during a large gathering at Bachhadapara, where a statue of Bhagwan Birsa Munda was being unveiled and installed. The complainant, Vikas, observed members of an organization intercepting vehicles of members of Parliament, Legislative Assembly, and other district officials arriving at the event. When efforts were made to remove these individuals with police security, an altercation ensued, leading to a scuffle and stone-pelting on the vehicles. During the incident, a security personnel suffered injuries. The FIR described the involvement of multiple persons, including the accused, who were identified by the complainant and witnesses. The investigation included recording statements from witnesses, interrogating the accused, and seizing the vehicle used in the incident. The complainant also captured the incident on video, which was submitted to the police (!) (!) .

The accused sought bail, which was initially rejected but later granted by the court. Disciplinary proceedings were also initiated against the accused, but these are not central to the legal issue before the court. The case proceeded to trial, where charges were framed under various sections of the Indian Penal Code and the SC/ST Act, including allegations of assault, threats, and other offences related to the incident. The investigation and subsequent proceedings did not establish that the accused had knowledge of the caste status of the victims or that the acts were motivated by caste-based reasons. The evidence on record was found insufficient to support the specific elements required for charges under the SC/ST Act, especially regarding caste awareness or caste-motivated intent (!) (!) (!) (!) (!) (!) (!) .

JUDGMENT :

SANJAY KAROL, J.

1. Leave Granted.

2. This appeal at the instance of the accused calls into question the correctness of the final judgment and order in Criminal Appeal No. 3945 of 2025, dated 3rd July 2025 by the High Court of Madhya Pradesh at Indore. In terms of the impugned judgment, the High Court dismissed the accused’s appeal arising out of the proceedings before the learned Special Judge¹ [Hereinafter referred to as ‘Trial Court’] Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989² [Hereinafter referred to as ‘SCST Act’] whereby his prayer for discharge under Section 227³ [SC ATR No. 28/2023] of the Code of Criminal Procedure, 1973⁴ [Hereinafter referred to as ‘CrPC’] was allowed only in part. The chargesheet that was filed upon completion of the investigation in FIR No. 0653 of 2022 dated 15th November 2022 registered at PS Bilpank, District Ratlam. The said chargesheet, being Chargesheet No. 1 of 2023 dated 16th February 2023, sent the matter up for trial against the accused on charges under Sections 294, 341, 383, 332, 146, 147, 336, 506, 333, 188, 326 of the Indian Penal Code, 1860⁵ [Hereinafter referred to as ‘IPC’] and Sections 3(1)(r), 3(2)(va) of the SCST Act as amended in 2015 and 2018, whereas charges were framed against him under the following Sections 147, 341, 427, 353, 332, 333, 326, 323, 352 read with 149 IPC and 3(2)(v), 3(2)(va) of the SCST Act.

3. The facts that culminated in the position as above were that on 15th November 2022 while a large congregation of persons had gathered at Bachhadapara, to witness the unveiling and installation of a statue of Bhagwan Birsa Munda - the complainant, namely, Vikas, had witnessed members of JAYS organisation intercept the vehicles of the members of Parliament and Legislative Assembly, as also other district officials, who were arriving at the event, and when they were attempted to be removed by the security, the said persons initiated an altercation and scuffle with them along with pelting stones at the vehicles. One security personnel namely Sandeep Chandel suffered injuries as a result. In the FIR, the persons involved were described as follows:

“….due to snatching and pelting of stone by these persons Gunman of Collector sir has suffered injuries near his nose and due to that injury blood oozed out. These persons were not ready to understand anybody’s advice and these were misbehaving with police personnel and were causing hurdle in government work and they were speaking irrelevant things and extending threats of life. Then me and other police personnel present there have made a video of all these persons. Out of these persons I know and identify D. Abhay Ohari Resident of Ratlam, D. Anand Rai Resident of Ratlam, Kamal Bhuriya Resident of Dharad, Manoj Parmar Resident of Dharad, Kishan Sighad Resident of Amleti, Dilip Bhuria Resident of Dharad, Anil Ninama, Resident of Satrunda, Sanjay Girwal Resident of Bhati Badodiya, Ajay Son of Kailash Bheel Resident of Dharad, Vijay Son of Shambhu Lal Bhuria Resident of Nalkui, Chhagan Lal Son of Choga Lal Meena Resident of Patrakar Colony Jawra, Mohan Singh Son of Mann Singh Dewda Resident of Lambi Sadadi Rani Singh Vilesh Kharadi Resident of Lambi Sadadi Baazna, Gopal Waghel Resident of Nagra, Gopal Ninama, Resident of Kundal, Deepak Ninama Resident of Vinobha Nagar, Ratlam, Chhotu Bhabhar Resident of Jamthun, Jitendra Katariya Resident of Surajpur and Kalu Baarot Resident of Shubham Shri Colony Ratlam, 40-50 more persons were also accompanying them. These persons have jammed the road for about 01 hours…”

It is also important to note the role of these persons as described in the chargesheet, which, obviously, is a document that signals the completion of the investigation. It essentially is a recapitulation of the statement of the complainant, and it records that during the investigation statement of the complainant and witnesses was recorded and after which the accused persons were separately