A Scheduled Castes Commission cannot adjudicate criminal charges or declare offences proved.

The petitioner, an Assistant Professor at Government College, Barpali, Korba, challenged the Chhattisgarh State Scheduled Castes Commission’s recommendation dated 16 March 2021 directing registration of an FIR against him under Section 3(1) of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989.

The complaint was filed by Respondent No. 5 after the petitioner allegedly caught her cheating in an examination. She subsequently alleged that the petitioner harassed and pressured her by using the cheating incident as a pretext.

The petitioner replied to the Commission’s notice and relied upon an earlier inquiry in which the allegations had allegedly been found false. Despite this, the Commission recorded that the charge under the 1989 Act was proved and recommended registration of an FIR.

1. Whether the Chhattisgarh State Scheduled Castes Commission exceeded its jurisdiction by recording that the charge under Section 3(1) of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989, was proved.

2. Whether the Commission could direct registration of an FIR after conducting an inquiry, or whether its role was limited to recording factual findings and making recommendations to the competent authorities.

The Court applied the principle that a statutory or constitutional commission empowered to inquire into complaints and investigate deprivation of rights may collect evidence, requisition documents, and record factual findings, but cannot adjudicate the rights or liabilities of parties or exercise powers reserved for a criminal court.

Relying on Bhabani Prasad Jena v. Convenor Secretary, Orissa State Commission for Women, (2010) 8 SCC 633, the Court held that such commissions may take up grievances with concerned authorities for remedial action but possess no adjudicatory jurisdiction.

It further relied on Mumbai Port Authority v. National Commission for Scheduled Castes, 2026 SCC OnLine SC 1398, which affirmed that the powers of a commission, including powers analogous to those of a civil court, are limited to inquiry and do not authorise it to pass binding orders in furtherance of its factual findings.

The Court also relied on All India Indian Overseas Bank SC and ST Employees’ Welfare Association v. Union of India, (1996) 6 SCC 606, and Shridhar C. Shetty v. Additional Collector and Competent Authority, (2020) 9 SCC 537, for the principles that procedural powers cannot be expanded into substantive adjudicatory powers and that a statutory authority must act within the limits of its enabling statute.

The Commission was competent to inquire into the complaint and, if appropriate, place its factual assessment before the competent governmental or investigative authority.

However, by expressly holding that the charge against the petitioner under Section 3(1) of the 1989 Act was “proved,” the Commission effectively determined criminal liability, a matter falling within the jurisdiction of the criminal court.

Its recommendation was therefore not merely recommendatory in substance.

The Commission’s power to inquire and make recommendations could not be construed as empowering it to conclusively determine the commission of an offence or direct action on the basis of such adjudication.

The impugned recommendation dated 16 March 2021 was therefore set aside.