Abuse within a private cattle shed in the presence of only relatives lacks the "public view" required for SC/ST Act offenses.

The Petitioner, who purchased agricultural land in 2015, had a history of disputes with the local Katkari community (Scheduled Tribe) regarding land boundaries and access to a water hand pump.

After the Petitioner fenced his land and filed a police complaint regarding the theft of fencing materials, the Respondent No. 2 (complainant) alleged that on November 25, 2022, the Petitioner entered his cattle shed and hurled caste-based abuses in the presence of family members and one villager.

An FIR was registered on December 27, 2022—thirty days after the alleged incident—under Sections 3(1)(r) and 3(1)(s) of the SC/ST (Prevention of Atrocities) Act and Section 504 of the IPC.

The Petitioner sought quashing of the FIR, contending the case was maliciously filed to settle land disputes.

Whether the alleged caste-based insults occurred within "public view" as required to constitute an offence under the SC/ST Act.

Whether the criminal proceedings were maliciously instituted with an ulterior motive to wreak vengeance, warranting quashing under Article 226 and Section 482 of the Cr.P.C.

The Court applied Sections 3(1)(r) and 3(1)(s) of the Scheduled Castes and the Scheduled Tribes (Prevention of Atrocities) Act, 1989, which require intentional insult or intimidation to be made in a place within "public view".

It relied on the precedent set in *Swaran Singh v. State* (2008), establishing that "public view" requires the presence of independent witnesses, excluding close relatives or friends of the complainant.

The Court invoked the guidelines from *State of Haryana v. Bhajan Lal* (1992), specifically Category 7, which permits quashing of proceedings that are manifestly attended with mala fides or maliciously instituted for wreaking vengeance due to a private grudge.

The Court observed that the alleged incident took place within a private cattle shed, which does not constitute a "public place".

Applying the *Swaran Singh* doctrine, the Court noted that all witnesses present were either close relatives or interested parties (friends), meaning the incident did not occur within "public view".

Furthermore, the Court highlighted a 30-day unexplained delay in filing the FIR.

The timeline revealed that the FIR followed legal actions taken by the Petitioner, including a theft complaint and a Grampanchayat notice sent to the Respondent for encroachment.

Consequently, the Court reasoned that the criminal case was a retaliatory measure intended to pressure the Petitioner regarding the land dispute rather than a bona fide complaint of caste-based atrocity.

The High Court allowed the Petition and quashed FIR No. 189 of 2022 registered with Pali Police Station.

Rule was made absolute, confirming that the proceedings were an abuse of the process of law.