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Karnataka High Court Quashes SC/ST Act FIR Against Company Officials, Says Complaint Followed Disciplinary Action and Industrial Dispute

Shivam Y.

The Karnataka High Court quashed an FIR filed under the SC/ST Act against company officials, holding that the complaint appeared linked to an ongoing disciplinary dispute and amounted to misuse of criminal proceedings. - B.S. Jagadish & Ors. v. State of Karnataka & Anr. (connected with Madhukar Jois Y.V. & Anr. v. State of Karnataka & Anr.)

Karnataka High Court Quashes SC/ST Act FIR Against Company Officials, Says Complaint Followed Disciplinary Action and Industrial Dispute
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The Karnataka High Court has quashed criminal proceedings initiated against five officials of Malnad Alloy Castings Private Limited, including its Managing Director, Executive Director, CEO and other senior employees, after finding that the complaint appeared to have been lodged in the backdrop of a disciplinary dispute between the company and one of its employees.

Justice M. Nagaprasanna allowed two connected criminal petitions and set aside Crime No. 39/2025 registered at Bhadravathi Police Station under provisions of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act and the Bharatiya Nyaya Sanhita.

Background of the Case

The dispute arose after the complainant, a production supervisor who had worked with the company for nearly 18 years, was issued a show-cause notice in December 2024. The company alleged negligence during production operations that had allegedly resulted in financial loss.

The employee denied the allegations and submitted a detailed explanation. When the company found the response unsatisfactory, it appointed an Enquiry Officer and initiated departmental proceedings.

Before the inquiry could progress, the employee approached the Industrial Tribunal challenging the show-cause notice and also sought reliefs relating to alleged caste-based discrimination. However, the Tribunal declined to grant immediate ex parte relief and issued notice to the company.

Shortly thereafter, on February 19, 2025, a criminal complaint was lodged against the company's officials, alleging intimidation, wrongful conduct and caste-based abuse. Based on the complaint, Crime No. 39/2025 was registered under the SC/ST Act and other penal provisions.

After examining the sequence of events, the High Court noted that the complainant had worked in the company for almost two decades and that no earlier incidents of caste-based abuse had been cited before the disciplinary proceedings began.

The Court observed that the timing of the complaint could not be ignored.

Justice Nagaprasanna stated that when the chain of events was examined, “the unmistakable inference” was that the complaint had been filed after the issuance of the show-cause notice and appointment of an Enquiry Officer. The Court further observed that the criminal case appeared to be a reaction to the departmental action taken by the employer.

The judge remarked that the complaint had to be viewed through the lens of an attempt to exert pressure in the ongoing dispute and questioned how the FIR was registered without verifying the factual basis of the allegations.

The High Court referred to the Supreme Court's decisions in Gulam Mustafa v. State of Karnataka and Hitesh Verma v. State of Uttarakhand.

Referring to those rulings, the Court reiterated that while the SC/ST Act serves an important constitutional purpose, courts can intervene where criminal proceedings appear to be an abuse of process or where allegations do not disclose the essential ingredients of the offence.

The Court also noted the Supreme Court's caution that stringent provisions should not be invoked mechanically and that investigating authorities must satisfy themselves that the statutory requirements are prima facie attracted before registering such cases.

Concluding that the allegations, even when viewed in the context of the materials on record, did not justify continuation of the criminal proceedings, the High Court held that the case represented a misuse of the provisions of the SC/ST Act and criminal law.

Allowing both petitions, Justice Nagaprasanna ordered:

“The criminal petitions stand allowed.”

The Court further directed:

“The Crime No.39/2025, now pending before the IV Additional District and Sessions Judge, Shivamogga (sitting at Bhadravathi), qua the petitioners, stand quashed.”

Accordingly, all proceedings against the petitioners in Crime No. 39/2025 were brought to an end.

Case Details

Case Title: B.S. Jagadish & Ors. v. State of Karnataka & Anr. (connected with Madhukar Jois Y.V. & Anr. v. State of Karnataka & Anr.)

Case Number: Criminal Petition No. 3478 of 2025 c/w Criminal Petition No. 2990 of 2025

Judge: Justice M. Nagaprasanna

Decision Date: June 4, 2026

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