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

The Supreme Court of India has affirmed a judgment by the High Court for the State of Telangana and Andhra Pradesh, which had quashed criminal proceedings against a Mandal Revenue Officer (MRO) and a Sub-Inspector of Police under the Scheduled Castes and the Scheduled Tribes (Prevention of Atrocities) Act, 1989 (SC/ST Act). The case stemmed from a prolonged land allotment dispute and alleged false implication.

The appellant's complaint originated from a land allotment dispute in Duvva village, where plots earmarked for Scheduled Caste/Scheduled Tribe beneficiaries were allegedly manipulated for upper-caste individuals by Respondent No. 2 (the MRO) at the behest of Accused No. 3 (a theatre proprietor). The appellant, a Junior Accountant, claimed he was falsely implicated in a criminal case (a group clash between two Scheduled Caste groups in Kothamalapalli village) in retaliation for his objection to the land allotment. He asserted that his name was added to the charge sheet later, despite his proven absence from the village at the time of the incident. Although the criminal proceedings against the appellant were eventually dropped, he subsequently filed a complaint against Respondent No. 1 (the Sub-Inspector of Police and investigating officer), Respondent No. 2, and Accused No. 3, alleging a conspiracy to falsely implicate and harass him due to his Scheduled Caste identity, leading to offences under the SC/ST Act.

The High Court allowed the petition by the respondents, quashing these proceedings. The appellant challenged this, arguing that the High Court exceeded its jurisdiction under Section 482 of the Code of Criminal Procedure (CrPC) by engaging in a detailed evaluation of evidence, which should have been left to the trial court, especially given the "overwhelming evidence" against the respondents.

Conversely, Respondent No. 2 (the MRO) argued that their actions regarding land allotment were in accordance with government guidelines and superiors' instructions, without any mala fide intent. They contended that the appellant's complaint was motivated by revenge, delayed, and time-barred. It was emphasized that the initial criminal case against the appellant involved an intra-caste clash, not one driven by caste-based malice by the respondents. Furthermore, the MRO's actions were based on official directives, not independent discretion or malicious intent.

The Supreme Court, after considering the arguments and evidence (noting that Respondent No. 1 had passed away during the appeal), dismissed the appeal. The Court concurred with the High Court's findings, concluding that the prosecution against the respondents lacked the crucial element of "mala fide intention." It was noted that the initial complaint against the MRO regarding land allotment was found to be incorrect after a detailed inquiry. Importantly, the Court highlighted that the criminal case in which the appellant was implicated was a dispute between two Scheduled Caste groups, negating the claim that his involvement by the respondents was due to his Scheduled Caste status with malicious intent. The Court stressed that mere allegations of malice or multiple pending litigations are insufficient to establish offences under the SC/ST Act.

Citing precedents like Masumsha Hasanasha Musalman v. State of Maharashtra and Dr. Subhash Kashinath Mahajan v. State of Maharashtra, the Supreme Court reiterated that the SC/ST Act should not be misused to settle personal scores or harass individuals, particularly public servants, and that courts should intervene to prevent such misuse.

The Supreme Court found no fault with the High Court's conclusions, stating that the impugned order was based on a proper appreciation of pleadings and correct application of law. The appeal was therefore dismissed, upholding the quashing of proceedings against the respondents.

  Code of Criminal Procedure, 1973