Does the SC/ST Act Apply to Same-Caste Conflicts? High Court Weighs In

In a significant order clarifying the application of the Scheduled Castes and the Scheduled Tribes (Prevention of Atrocities) Act, 1989, the High Court of Punjab and Haryana at Chandigarh has granted regular bail to a man accused of assaulting a worker in his factory. The case, Rahul Bundela @ Rahul v. State of Haryana , brought into sharp focus the legal complexities surrounding the prosecution of individuals under the SC/ST Act when both the victim and the accused share a similar minority caste background.

The Backdrop of the Dispute

On April 7, 2024, the complainant, Gurudayal, alleged he was attacked in his factory in Hansi by a group of individuals using rods, sticks, and iron pipes. The victim, who belongs to a Scheduled Caste, claimed the assailants used caste-based slurs and threatened his life. An FIR was subsequently registered under various sections of the Indian Penal Code ( IPC ) and the SC/ST Act.

The appellant, Rahul Bundela, was arrested on June 5, 2025—over 400 days after the initial FIR was lodged. His application for regular bail was initially dismissed by the Additional Sessions Judge in Hisar, prompting an appeal to the High Court under Section 14-A (2) of the SC/ST Act.

Arguments From Both Sides

Defense counsel argued that the FIR was lodged with an unexplained three-day delay and noted that the appellant himself holds a formal certificate identifying him as a member of the "Deprived Scheduled Caste." The defense contended that if all parties fall under the protection of the same legislative framework, the provisions of the SC/ST Act are fundamentally inapplicable. Furthermore, it was highlighted that the prosecution failed to attribute any specific injury or weapon usage to the appellant, and CCTV evidence did not definitively place him in an aggressive role.

Conversely, the State of Haryana opposed the bail, asserting that the appellant was part of an unlawful assembly that caused grievous injuries through criminal trespass and intimidation. The prosecution maintained that the severity of the allegations necessitated continued pre-trial detention.

Key Observations of the Court

The Court’s decision rested on an analysis of the appellant's status and the specific nature of the evidence provided. Justice Manisha Batra noted that the appellant's own background required a deeper examination of the applicability of the Act:

• "The appellant is in custody since 05.06.2025. No specific injury has been attributed to him. Neither any specific weapon was alleged to be carried by him at the time of occurrence."
• "He is falling under Deprived Scheduled Caste category and as such, it is to be considered as to whether the provisions of SC/ST Act are applicable against him or not?"
• "Keeping in view the period of incarceration of the appellant, the nature of attributions made to him and the above discussed facts... the Court is of the considered opinion that no useful purpose would be served by keeping the appellant in custody any more."

The Verdict and Its Implications

The High Court proceeded to set aside the lower court’s order, allowing the appellant's bail application. By emphasizing the lack of specific evidence linking the appellant to the violence and questioning the viability of invoking the SC/ST Act in what appeared to be a same-caste conflict, the Court has potentially set a precedent for future bail hearings involving similar circumstances.

The ruling serves as a reminder that while the SC/ST Act provides robust protections against caste-based discrimination, its application requires precise alignment with the specific factual matrix of the case. The appellant has been ordered to be released upon furnishing satisfaction of the relevant security bonds, bringing an end to his current period of incarceration.