Absence of specific allegations of caste discrimination precludes National Commission for Scheduled Castes from exercising Article 338 jurisdiction.

Respondent No. 2, Manas Ranjan Behera, filed a complaint with the National Commission for Scheduled Castes (NCSC) alleging "caste-based discrimination" by officials of the Petitioner insurance company.

The grievance arose after the Petitioner repudiated an insurance claim filed by Respondent No. 2 following losses incurred during Cyclone Fani.

The Respondent alleged mental harassment and corruption, claiming officials demanded a bribe to process the file.

Consequently, the NCSC issued a notice dated 22.06.2023 to the Petitioner.

The Petitioner challenged this notice and the NCSC’s jurisdiction before the High Court of Delhi.

1. Whether the complaint made by Respondent No. 2, if taken at face value, discloses any matter that falls within the jurisdiction of the National Commission for Scheduled Castes under Article 338 of the Constitution of India.

Article 338 of the Constitution of India, which empowers the NCSC to investigate matters relating to safeguards for Scheduled Castes and inquire into specific complaints regarding the deprivation of rights and safeguards.

The Court also referenced All India Indian Overseas Bank SC and ST Employees Welfare Association v. Union of India, National Hydroelectric Power Corporation Ltd. v. National Commission for Scheduled Tribes, and Indian Oil Corporation Ltd. v. National Commission for Scheduled Tribes, which establish the limits of the Commission’s powers.

The core principle is that the Commission's jurisdiction is only triggered when there is an element of caste discrimination or violation of specific constitutional/statutory safeguards.

The Court analyzed the body of the complaint and found that, despite the label "caste-based discrimination," the allegations lacked specific averments showing the Respondent was treated adversely because of his caste.

There was no evidence that the insurance policy was denied due to the Respondent's status, nor were there allegations of violations regarding reservation policies or statutory protections meant for Scheduled Castes.

The Court observed that the dispute was essentially a commercial transaction involving the repudiation of an insurance claim and allegations of bribery, rather than a deprivation of caste-based rights.

Since the complaint failed to disclose the bare facts necessary to invoke Article 338, the Court determined the NCSC acted without jurisdiction.

The court answered the issue in the negative, stating the dispute was a commercial matter to be adjudicated by a court of competent jurisdiction.

Accordingly, the Court quashed the notice dated 22.06.2023, set aside all consequential orders, and rejected the underlying complaint.