Abuses uttered within private factory premises do not constitute offences in "public view" or a "public place."

The applicant, a legal advisor for a manpower firm, sought to quash an FIR filed under Sections 294(b) and 114 of the IPC and Sections 3(1)(r) and 3(1)(s) of the Atrocity Act.

The de facto complainant alleged that while visiting a company office to discuss compensation for his son’s work injury, the applicant and others hurled caste-based abuses and forced him to leave the premises.

The applicant contended the FIR was a malicious "arm-twisting tactic" to extort money, noting that the firm had already covered all medical expenses for the son's injury.

During the pendency of the case, the original complainant passed away, and his heirs did not appear despite being served.

1. Whether the alleged caste-based insults occurred within "public view" as required to attract Sections 3(1)(r) and 3(1)(s) of the Atrocity Act.

2. Whether the factory premises and private office area constitute a "public place" under Section 294(b) of the IPC.

3. Whether the FIR constitutes an abuse of the process of law deserving quashment under Section 482 of the CrPC.

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

The Court relied on Swaran Singh v. State (2008), which distinguishes "public place" from "place within public view," noting that insults inside a building without public presence do not satisfy the Atrocity Act.

The Court further applied Keshaw Mahto v. State of Bihar (2026), holding that mere knowledge of a person's caste is insufficient; there must be an intent to humiliate.

For the IPC charges, Section 294(b) was applied, requiring "obscene acts or words" in or near a "public place".

The Court followed the guidelines in State of Haryana v. Bhajan Lal (1992) for quashing proceedings.

The Court found that the alleged incident occurred within the private precincts of a factory and outside a Managing Director's office, not in "public view".

Investigation papers revealed that while the complainant was accompanied by friends, their statements did not corroborate the specific slurred words alleged in the FIR; one friend was even standing outside the building entirely.

Because the utterances were not audible or visible to the general public, the fundamental ingredients of Sections 3(1)(r) and 3(1)(s) of the Atrocity Act were missing.

Regarding the IPC, the Court reasoned that a private factory office does not constitute a "public place" under Section 294(b).

The Court concluded that the allegations were inherently improbable and appeared to be maliciously instituted for vengeance.

The Court allowed the application and quashed the FIR (CR No. 11197006220377 of 2022) and all consequential proceedings against the applicant. Rule was made absolute.