A prima facie SC/ST Act offence bars anticipatory bail where caste-based humiliation is alleged in public view.

The appellants challenged the Special Judge’s order dated 24 August 2026 refusing anticipatory bail and sought relief under Section 14-A(2) of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989.

The FIR alleged that the appellants and others entered the complainant’s agricultural field, assaulted members of his family, used caste-based abuse, and attempted to outrage the modesty of the complainant’s sister.

The appellants relied on a land dispute and prior revenue proceedings to argue that they had been falsely implicated; the State opposed bail, relying on the FIR and witness statements.

Whether the FIR and supporting material disclosed a prima facie offence under the SC/ST Act, such that the statutory bar on anticipatory bail applied.

Whether the appellants were entitled to anticipatory bail in light of their land-dispute defence and the allegations against them.

Section 14-A(2) of the SC/ST Act provides the appellate route invoked by the appellants; Sections 18 and 18-A bar anticipatory bail under Section 438 of the Code of Criminal Procedure where a prima facie offence under the SC/ST Act is disclosed.

Under Prathvi Raj Chauhan v. Union of India, the bar does not apply if the FIR and supporting material fail to disclose such a prima facie case.

Kiran v. Rajkumar Jivraj Jain requires the court to examine the complaint’s averments to determine whether an offence under Section 3(1) of the SC/ST Act is prima facie made out; specific caste-based intimidation intended to humiliate weighs against anticipatory bail.

At the bail stage, the court determines whether a prima facie case is disclosed and must not conduct a mini-trial or test the truth of competing versions.

The Court found specific allegations that the appellants participated in the assault, used caste-based insults, and caught and dragged the complainant’s sister while attempting to outrage her modesty; her statement under Section 180 of the BNSS supported that allegation.

As the alleged incident occurred in a place within public view, the Court held that an intention to humiliate could not be ruled out at this stage.

The appellants’ claim that the case arose from a land dispute and that the complainant’s family were the aggressors raised a competing factual account, but resolving its truth would amount to a mini-trial, which was impermissible at the bail stage.

The criminal appeal was dismissed.