23 July 2025 Criminal Appeals & Suspension of Sentence >> Criminal Law  

The Supreme Court recently dismissed an appeal of Konde Nageshwar Rao v/s A. Srirama Chandra Murty & Another challenging a High Court's decision to quash criminal proceedings against two individuals—a police officer and a Mandal Revenue Officer (MRO)—who were accused of offenses under the Scheduled Castes and the Scheduled Tribes (Prevention of Atrocities) Act, 1989 (SC/ST Act). The judgment, which affirmed the High Court's ruling, underscored the importance of distinguishing between personal disputes and caste-based offenses, particularly when a statute like the SC/ST Act is invoked.

Background of the Dispute:

The case originated from a long-standing land allotment dispute in Duvva village, where the appellant, a member of the Scheduled Caste, alleged that the MRO (Respondent No. 2) and a local proprietor conspired to allot plots meant for Scheduled Caste/Scheduled Tribe beneficiaries to upper-caste individuals.

The appellant's complaint against the MRO regarding this wrongful allotment was a key point of contention. The appellant claimed that in retaliation for his complaint, he was falsely implicated in a separate criminal case related to a clash between two Scheduled Caste groups that occurred in 1995. The Sub-Inspector of Police (Respondent No. 1) was the investigating officer in that case.

Although the appellant was initially not named in the First Information Report (FIR), his name appeared in the charge sheet. The appellant argued that this was a malicious act intended to harass him because of his caste. The criminal proceedings against the appellant were later dropped after an investigation found that he was not present at the scene of the crime.

Following the withdrawal of the criminal case against him, the appellant filed a complaint under the SC/ST Act against the police officer, the MRO, and the proprietor, accusing them of conspiring to falsely implicate him. After an investigation by a Deputy Superintendent of Police, a charge sheet was filed, leading to the commencement of criminal proceedings against the respondents.

High Court's Decision to Quash Proceedings:

The respondents challenged these proceedings by filing a petition under Section 482 of the Code of Criminal Procedure (CrPC), which allows a High Court to quash proceedings to prevent the abuse of the legal process. The High Court allowed the petition, quashing the criminal proceedings against the police officer and the MRO. This decision was then challenged by the appellant in the Supreme Court.

The appellant's counsel argued that the High Court had overstepped its jurisdiction under Section 482 CrPC. The counsel contended that there was overwhelming evidence and 39 witnesses to support a prima facie case against the respondents, and that the High Court should have left the evaluation of evidence to the trial court.

Supreme Court's Analysis:

The Supreme Court, however, upheld the High Court's judgment, finding no fault in its reasoning. The court's decision hinged on several key observations:

• Lack of Mala Fide Intent: The court noted that the initial complaint against the MRO regarding the land allotment was found to be based on a misunderstanding, as a detailed inquiry revealed that the allotments were made according to government instructions. Furthermore, the allotments were eventually canceled, removing any motive for the MRO to retaliate.
• Intra-Caste Dispute: The court highlighted that the 1995 criminal case, in which the appellant was falsely implicated, was a clash between two groups belonging to the Scheduled Caste. The court reasoned that since the conflict was intra-caste, the involvement of the appellant could not have been motivated by caste-based malice.
• Absence of Specific Evidence: The court found that the appellant's allegations were "bald" and lacked specific instances or evidence to prove a conspiracy or malicious intent to harm him on the basis of his caste. The court noted that merely because various litigations were pending between the parties, it could not be presumed that the prosecution was malicious.
• Misuse of the SC/ST Act: Citing previous judgments, the Supreme Court reiterated that the SC/ST Act is not a tool to settle personal scores. The court emphasized that for the act to apply, the offense must have been committed solely on the basis of the victim's caste status. The court also cited a previous observation that there has been an "alarming increase in false complaints" under the SC/ST Act, particularly against public servants, and that such misuse must be stopped at an early stage.

In conclusion, the Supreme Court found that the High Court's decision was based on a proper appreciation of the facts and the law. The court held that the allegations, even if taken at face value, did not disclose the essential elements of an offense under the SC/ST Act. The appeal was therefore dismissed, affirming the quashing of the criminal proceedings.