Absence of specific caste-based slurs and lack of public view precludes prosecution under the SC/ST Act.

The petitioners filed an application under Section 482 of the CrPC to quash FIR C.R. No. 11206043220248 of 2022. The complainant alleged that on 02.04.2022, while at a shop, the applicants (petitioners) threw caste-based slurs and physically assaulted him because he questioned the high cost of their goods

Petitioner No. 2 (Dilipbhai) contended he was not present at the scene, supported by his testimony as a witness in a cross-FIR where the complainant was convicted

The State conceded that investigation records did not show specific slurs or the presence of Petitioner No. 2

1. Whether the FIR discloses the necessary ingredients to constitute offenses under Sections 3(1)(r), 3(1)(s), and 3(2)(v)(a) of the SCST Act when specific insulting words are absent from the record

2. Whether the criminal proceedings against Petitioner No. 2 should be quashed due to lack of presence at the scene and potential malicious prosecution

Section 482 of the CrPC regarding the inherent powers of the High Court to prevent abuse of the process of law.

State of Haryana v. Bhajan Lal: established that an FIR can be quashed if the allegations, even if taken at face value, do not disclose a cognizable offense or are maliciously instituted

Haji Iqbal @ Bala v. State of U.P.: mandates that courts look "between the lines" of an FIR to identify frivolous or vexatious litigation motivated by personal vendettas

The court found that the FIR contained vague allegations of "caste-based slurs" without specifying the exact words used, which is a prerequisite for attracting Sections 3(1)(r) and 3(1)(s) of the SCST Act

Regarding Petitioner No. 2, the court noted that evidence from a related criminal case—where the respondent was convicted—conclusively showed Petitioner No. 2 was not present at the time of the incident

Applying the Bhajan Lal and Haji Iqbal standards, the court determined that the allegations against Petitioner No. 2 were inherently improbable and that the SCST Act charges against Petitioner No. 1 lacked the necessary factual ingredients to proceed

Regarding Petitioner No. 1, the court quashed the charges specifically under Sections 3(1)(r), 3(1)(s), and 3(2)(v)(a) of the SCST Act, while directing the investigation to continue for the remaining IPC offenses (Sections 323, 504, 114). Rule was made absolute to this extent.