The Telangana High Court has quashed criminal proceedings pending before a Special Sessions Court in Ranga Reddy district, ruling that allegations made under the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act did not meet the legal requirements. Justice E.V. Venugopal delivered the order in Criminal Petition No.3799 of 2021, noting that continuing the trial would amount to an "abuse of process of law."
Background of the Dispute
The case originated from a complaint lodged in 2019, where the de-facto complainant, belonging to a Scheduled Caste, alleged humiliation and harassment by his wife and her family. The couple had married in 2014 in an inter-caste marriage, but soon faced marital discord over lifestyle issues and caste-related disagreements. In 2018, the complainant claimed that he was abused with caste-based insults and threatened with false cases.
Based on his complaint, police registered offences under Section 504 of the IPC and Sections 3(1)(r) and 3(1)(s) of the SC/ST (POA) Act. However, the wife challenged the case, pointing out that the couple had already obtained a divorce decree in 2019 and that the allegations were part of personal disputes.
The High Court carefully examined whether the caste atrocity provisions applied in this case. It noted that for an offence under Sections 3(1)(r) and 3(1)(s) of the SC/ST Act to stand, the humiliation must occur in a public place or in public view.
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Justice Venugopal observed:
"There is no material to indicate that the alleged incident occurred in a public place or was witnessed by others. The acts complained of appear to have arisen out of domestic discord within the four walls of a private residence."
The Court relied on previous Supreme Court rulings in Hitesh Verma v. State of Uttarakhand (2020) and Sudhakar v. State (2018), both of which clarified that private disputes without public humiliation cannot be prosecuted under the SC/ST (POA) Act.
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Concluding that the allegations were purely matrimonial in nature and lacked the "public view" element, the Court quashed the proceedings in S.C. No.229 of 2020 pending before the Special Sessions Judge. The order emphasised that forcing the accused to undergo trial under such circumstances would be unjustified.
With this ruling, the High Court reiterated that while caste-based abuse is a serious offence, the law cannot be stretched to cover private disputes unless the statutory conditions are satisfied.
