The Karnataka High Court at Dharwad has refused to quash criminal proceedings against three factory owners accused under the SC/ST (Prevention of Atrocities) Act, holding that delay in filing the complaint cannot, by itself, invalidate the case.
The Court emphasized that when allegations disclose a prima facie offence, the matter must proceed to trial.
Background of the Case
The case arose from a complaint filed by a factory worker belonging to a Scheduled Caste. He alleged that on 6 April 2024, the owners of the factory abused him and another worker using caste-based slurs and threatened them with dismissal.
According to the complaint, the incident occurred at the dispatch section gate of the factory in Hubballi. The FIR, however, was registered nearly six months later, on 29 October 2024.
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The accused Shyam Mehta and his family members approached the High Court seeking quashing of the FIR, arguing that:
- The complaint was delayed and therefore unreliable
- It was motivated by an ongoing labour dispute and union strike
- The alleged incident took place inside factory premises, not in “public view”
The petitioners contended that the complaint was an abuse of legal process, filed to pressure management during an industrial dispute. They argued that the delay and surrounding circumstances showed mala fide intent.
On the other hand, the State and the complainant argued that the FIR clearly disclosed offences under the SC/ST Act and that such issues must be tested during trial, not at the quashing stage.
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Justice Hanchate Sanjeevkumar observed that while there was a delay of about six months, it could not automatically render the complaint false.
“The delay is a matter to be examined during trial,” the Court noted, adding that circumstances such as fear of losing employment could explain why a worker did not immediately approach the police.
The Court remarked:
“Just because there is delay in lodging the complaint, it cannot be a ground to suspect the prosecution case or to quash proceedings.”
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‘Public View’ Includes Workplace Settings
Addressing the argument that the incident did not occur in public view, the Court clarified the distinction between a “public place” and “public view.”
It held that even a private place like a factory can fall within “public view” if employees are present and can witness the incident.
“Employees present at the location are also members of the public,” the Court observed, concluding that the allegations satisfy the requirement under the SC/ST Act.
The Court rejected the argument that the complaint was linked to a union strike notice issued shortly before the FIR.
It held that:
“Linking the complaint with the strike appears to be mere coincidence,”
and added that such factual disputes must be examined during trial.
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After examining the complaint and surrounding circumstances, the Court found that the allegations, if taken at face value, disclose a prima facie case.
It ruled that:
- The delay does not justify quashing
- The ingredients of offences under the SC/ST Act are made out
- Disputed facts must be tested during trial
Accordingly, the High Court dismissed the criminal petition and allowed the proceedings to continue.
Case Details
Case Title: Shyam Mehta & Ors. v. State of Karnataka & Anr.
Case Number: Criminal Petition No. 100213 of 2025
Judge: Justice Hanchate Sanjeevkumar
Decision Date: 2 April 2026
