An acquittal cannot be reversed where the trial court’s view is plausible and supported by evidence.

On 13 July 2025, an altercation occurred between the appellant/complainant and the respondent-accused persons concerning the erection of fencing in the complainant’s field.

The complainant alleged that Matwar Yadav, his wife and daughter-in-law abused him in filthy language by referring to his caste.

The complaint was lodged on 14 July 2025, followed by registration of the FIR, arrest of the accused, investigation and filing of the charge-sheet.

The accused were prosecuted for offences under the Bharatiya Nyaya Sanhita, 2023 and Sections 3(1)(r), 3(1)(s) and 3(2)(va) of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989.

The prosecution examined nine witnesses, while the defence examined one witness.

The Special Judge, SC/ST Act, Janjgir, acquitted the accused by judgment dated 20 July 2026, holding that the prosecution failed to prove the charges beyond reasonable doubt.

The complainant consequently filed the present acquittal appeal.

Whether the evidence established that the accused intentionally insulted or intimidated the complainant, a member of a Scheduled Caste, by using caste-based words so as to attract Sections 3(1)(r) and 3(1)(s) of the SC/ST Act?

Whether the alleged abusive conduct constituted an offence under Section 296 of the Bharatiya Nyaya Sanhita, 2023?

Whether the trial court’s order of acquittal was perverse, illegal or otherwise liable to interference in an appeal against acquittal?

The Court considered the ingredients of Sections 3(1)(r), 3(1)(s) and 3(2)(va) of the SC/ST Act, which require proof of intentional insult, intimidation or caste-based abuse in the circumstances contemplated by the statute.

It also considered the alleged offence under Section 296 of the Bharatiya Nyaya Sanhita, 2023 concerning abusive or obscene conduct.

On the scope of appellate interference against acquittal, the Court relied on State of Rajasthan v. Kistoora Ram, 2022 SCC OnLine SC 984, holding that interference is justified only where the trial court’s view is impossible or perverse; where two views are reasonably possible, the acquittal should not be reversed.

It further relied on Jafarudheen v. State of Kerala, (2022) 8 SCC 440, which recognises the strengthened presumption of innocence following acquittal and requires thorough scrutiny before reversal.

The High Court found that the complainant’s evidence contained material admissions weakening the prosecution case.

He admitted that his written complaint did not mention that the quarrel had occurred on account of the alleged caste-based word, that he did not belong to the caste allegedly referred to, and that he had gone to intervene in the conduct of the accused persons.

The alleged eyewitness, PW-2, admitted that he had observed the incident from a distance of approximately 50 metres and had not intervened.

PW-3 stated that the accused had pointed towards the complainant and abused him, but he and the other witnesses left when the altercation began; his evidence was also considered in light of his prior connection with a criminal case and the accused persons’ support for the opposing party.

In these circumstances, the trial court concluded that the alleged word was not shown to have been used intentionally to insult or intimidate the complainant on the basis of caste.

The High Court held that this was at least a plausible view of the evidence and was neither perverse nor illegal.

The appellate court therefore could not substitute another possible view merely because conviction appeared arguable.

It held that the prosecution had failed to prove beyond reasonable doubt the intentional caste-based insult or intimidation required under the SC/ST Act, as well as the alleged offence under Section 296 of the BNS.

Since the trial court’s view was a possible and legally sustainable view of the evidence, the enhanced presumption of innocence arising from the acquittal was not displaced.

The acquittal appeal was accordingly dismissed, and the acquittal of the respondent-accused persons was affirmed.