2026 INSC 141 REPORTABLE IN THE SUPREME COURT OF INDIA CRIMINAL APPELLATE JURISDICTION CRIMINAL APPEAL NO. __________________ OF 2026 (Arising out of SLP (Crl.) No. 10711of 2025)

DR. ANAND RAI ... APPELLANT(S)

VERSUS STATE OF MADHYA PRADESH & ANR. … RESPONDENT(S)

J U D G M E N T

SANJAY KAROL, J.

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 3^rd July 2025 by the High Court of Madhya Pradesh at Indore. In terms of the Signature Not Verified impugned judgment, the High Court dismissed the accused’s Digitaly signed by

KANCHAN CHOUHAN

Date: 2026.02.11

Reason:

Judge , Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989 whereby his prayer for discharge under

3 4 Section 227 of the Code of Criminal Procedure, 1973 , was allowed only in part. The chargesheet that was filed upon completion of the investigation in FIR No. 0653 of 2022 dated 15^th November 2022 registered at PS Bilpank, District Ratlam. The said chargesheet, being Chargesheet No.1 of 2023 dated 16^th February 2023, sent the matter up for trial against the accused on charges under Sections 294, 341, 383, 332, 146, 147, 5

336, 506, 333, 188, 326 of the Indian Penal Code, 1860 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 15^th 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

1 Hereinafter referred to as ‘Trial Court’

2 Hereinafter referred to as ‘SCST Act’

3 SC ATR No. 28/2023

4 Hereinafter referred to as ‘CrPC’

5 Hereinafter referred to as ‘IPC’

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 documen