Anand Rai vs State of Madhya Pradesh

Judicial Analysis Court Copy Headnote Facts Arguments Court observation

2026 Supreme(SC) 153

SANJAY KAROL, N. KOTISWAR SINGH
Anand Rai – Appellant
Versus
State of Madhya Pradesh – Respondent

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.

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),