On a packed Tuesday morning in Court, the Supreme Court of India delivered a significant ruling in the case of Dr Anand Rai. The bench of Justice Sanjay Karol and Justice Nongmeikapam Kotiswar Singh set aside charges framed against him under the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, holding that there was no material to show caste-based intent or knowledge.
While the criminal case against him will continue under provisions of the Indian Penal Code (IPC), the top court made it clear that the special law meant to protect Scheduled Castes and Scheduled Tribes cannot be invoked without basic ingredients being present.
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Background of the Case
The case arose from an incident on November 15, 2022, in Ratlam district of Madhya Pradesh, during a public gathering for the unveiling of a statue of Birsa Munda. According to the FIR, members of an organisation allegedly blocked the vehicles of public representatives and officials. A scuffle followed, and a security personnel was injured.
An FIR was registered at Bilpank police station. A chargesheet followed, accusing several persons, including Dr Anand Rai, of offences such as unlawful assembly, assault on public servants, and causing injuries.
Charges were framed under various IPC provisions and also under Sections 3(2)(v) and 3(2)(va) of the SC/ST Act. Dr Rai challenged the framing of charges and sought discharge.
The trial court partly allowed his plea but retained the charges under the SC/ST Act. The Madhya Pradesh High Court refused to interfere. This led to the appeal before the Supreme Court.
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What Was the Legal Question?
Senior Advocate Kapil Sibal, appearing for Dr Rai, argued that there was no allegation in the FIR or witness statements that any caste-based insult was made or that the accused had knowledge of the complainant’s caste.
The core legal issue was simple: Can charges under the SC/ST Act survive if there is no material to show that the accused knew the victim belonged to a Scheduled Caste or Scheduled Tribe, or that the act was committed because of caste?
Court’s Observations
The bench closely examined the requirements of Sections 3(2)(v) and 3(2)(va) of the SC/ST Act. These provisions apply when an offence is committed against a person belonging to a Scheduled Caste or Scheduled Tribe, and the accused had knowledge of that fact.
The Court noted that the trial court itself had recorded that no witness had specifically stated which accused used casteist slurs. Despite that, charges under other provisions of the SC/ST Act were retained.
Justice Karol observed that the requirement of “knowledge” is not a formality. It is a foundational element.
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The bench remarked, “Once the knowledge on part of the alleged offender is in question, it is but certain that the charge cannot stand.”
It further pointed out that there was no clear averment in the complaint that the act was caste-motivated. Nor was there material showing that Dr Rai knew the caste identity of the complainant.
The Court said that merely because IPC offences may be made out on a prima facie reading, it does not automatically justify adding provisions of the SC/ST Act.
On the Role of the High Court
The bench was also critical of the manner in which the High Court handled the appeal under Section 14-A of the SC/ST Act.
An appeal under this section, the Court explained, is a first appeal on facts and law. The High Court is expected to independently examine whether the essential ingredients of the offence are disclosed.
However, in this case, the High Court’s judgment did not meaningfully deal with the SC/ST charges.
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“A mechanical affirmation of the order… would amount to a failure to exercise jurisdiction,” the bench said, stressing that appellate courts must apply their mind, especially when personal liberty is at stake.
On the Importance of Discharge
In a reflective closing, the Court reminded trial courts that framing of charge is not a routine step.
“The power to frame a charge is not meant to be exercised by default,” the bench observed. If the material on record does not disclose the ingredients of an offence, the court must have “the clarity and courage” to discharge the accused.
The judges noted that criminal prosecution itself carries stigma and stress. Allowing a case to proceed without legal basis can make “the process itself the punishment.”
The Decision
Allowing the appeal in part, the Supreme Court quashed the charges against Dr Anand Rai under the SC/ST Act.
The matter has been sent back to the trial court to proceed with the remaining IPC charges in accordance with law.
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The Court clarified that its observations are confined only to the provisions of the SC/ST Act and should not influence the trial on other charges.
Case Title: Dr Anand Rai v. State of Madhya Pradesh & Anr.
Case No.: Criminal Appeal arising out of SLP (Crl.) No. 10711 of 2025
Decision Date: February 10, 2026
