In a strong message on caste-based violence, the Supreme Court on Monday set aside a Bombay High Court order that had granted anticipatory bail to Rajkumar Jivraj Jain in a case involving assault and caste abuse. The top court made it clear that when an FIR discloses prima facie offences under the SC/ST (Prevention of Atrocities) Act, anticipatory bail cannot be granted.
Background
The case stems from a violent clash in Kapilapuri village of Dharashiv district on November 25, 2024. The complainant, Kiran, who belongs to the Matang community, alleged that a group of villagers led by Rajkumar Jain attacked him and his family for not voting as instructed in the assembly elections. According to the FIR, the accused used casteist slurs, beat him with iron rods, threatened to burn down his house, and even assaulted his mother and aunt. “Mangatyano, you have become very arrogant,” the complaint quoted Jain as saying, before striking him.
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The Sessions Court at Paranda had earlier denied anticipatory bail to Jain, citing specific caste-related abuses and corroboration by witnesses. But in April 2025, the Aurangabad bench of the Bombay High Court reversed that decision, calling the case exaggerated and politically motivated.
Court’s Observations
Hearing the appeal, the Supreme Court bench led by Justices B.R. Gavai, K. Vinod Chandran, and N.V. Anjaria pulled up the High Court for virtually conducting a “mini-trial” at the bail stage.
The bench noted, “The use of the word ‘Mangatyano’ was with a clear intention to humiliate the complainant because he belonged to the Scheduled Caste community.”
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The judges emphasised that Section 18 of the SC/ST Act expressly bars anticipatory bail when caste-based atrocities are alleged. “The High Court overlooked the statutory bar and proceeded to analyse witness statements in detail, which was impermissible,” the court observed.
It further clarified that the alleged assault happened outside the complainant’s house, making it a place “within public view” as required under the law. The court said recovery of weapons and damaged items supported the FIR version.
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Decision
The apex court cancelled Jain’s anticipatory bail, holding that the Bombay High Court had committed “a manifest error.” The order of April 29, 2025 was quashed, and Jain now faces arrest. However, the bench clarified that its findings were only prima facie and the trial must proceed on its own merits, without being influenced by these observations.
Case Title: Kiran vs. Rajkumar Jivraj Jain & Anr.
Case Type: Criminal Appeal (from SLP (Crl.) No. 8169 of 2025)
Decision Date: 1 September 2025
