The Supreme Court has quashed proceedings under Sections 3(1)(r) and 3(1)(s) of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989 against a school manager, holding that the material on record did not establish that the alleged caste-based remarks were made “within public view”.
A Bench comprising Justice Vikram Nath and Justice Sandeep Mehta delivered the judgment on August 20, 2026, in Ramkrishna Chauhan v. State of U.P. & Anr. The Court, however, allowed the remaining proceedings under the Indian Penal Code to continue.
Background of the Case
The matter arose from an FIR registered on January 25, 2020, against Ramkrishna Chauhan and others under Sections 147, 323, 342 and 504 of the IPC, along with Sections 3(1)(r) and 3(1)(s) of the SC/ST Act.
According to the prosecution case, the complainant approached Chauhan, who was the manager of a school, after his son was injured in a quarrel with another student. It was alleged that an altercation followed and that Chauhan and other school staff members assaulted the complainant. The FIR also contained an allegation of caste-based abuse.
The Special Judge took cognizance of the offences in August 2022. The Allahabad High Court later declined to interfere, finding that the allegations and witness statements disclosed a prima facie case.
The appellant then approached the Supreme Court.
Supreme Court Examines ‘Public View’ Requirement
The central issue before the Supreme Court was whether the alleged caste-based remarks satisfied the requirement under Sections 3(1)(r) and 3(1)(s) that the alleged insult, intimidation or caste-based abuse must take place at a place “within public view”.
The Court noted that the incident was alleged to have taken place inside a room in the school. The investigating officer’s site plan identified the place of occurrence as room “A” and indicated that it was an enclosed room without a window or public access.
Referring to its earlier decisions, the Court explained that a place is within public view when members of the public can witness or hear the alleged utterance.
“If the alleged offence takes place within the four corners of the wall where members of the public are not present, then it cannot be said that it has taken place at a place within public view.”
Witness Statements Did Not Establish Public View
The Supreme Court also examined statements recorded during the investigation from four teachers of the school.
The witnesses described an altercation and scuffle between the parties at the school office. However, none of them stated that they were inside the room when the alleged caste-based remarks were made or that they had heard such remarks. The Court therefore found that their presence elsewhere on the school premises did not establish that the alleged utterances were made within public view.
The Court further observed that the FIR and the complainant’s statement did not attribute any specific caste-based words or slurs to the appellant. The allegation remained general in nature.
Court’s Decision
The Bench clarified that although a court is not expected to conduct a detailed assessment of evidence while taking cognizance, the basic ingredients of the alleged offence must still emerge from the material available on record.
The Court held that the essential requirement of “public view” was not established in the present case. It therefore concluded that Sections 3(1)(r) and 3(1)(s) of the SC/ST Act were not prima facie made out against the appellant.
Accordingly, the Supreme Court allowed the appeal and set aside the Allahabad High Court’s judgment. The proceedings arising from FIR No. 37 of 2020, insofar as they concerned Sections 3(1)(r) and 3(1)(s) of the SC/ST Act against the appellant, were quashed.
The proceedings relating to the remaining IPC offences were directed to continue.
Case Details
Case Title: Ramkrishna Chauhan v. State of U.P. & Anr.
Case Number: Criminal Appeal arising out of SLP (Criminal) No. 5113 of 2023
Judges: Justice Vikram Nath and Justice Sandeep Mehta
Decision Date: August 20, 2026
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