Caste-based insults must be directed at victim's identity to constitute an offence under the SC/ST Act.

The State of Gujarat appealed a judgment dated 22.05.2012 by the Special Judge (Atrocity), Mahesana, which acquitted the respondents of charges under Sections 323, 504, 506(2), and 114 of the IPC, Section 3(1)(10) of the SC/ST (Prevention of Atrocities) Act, and Section 135 of the Bombay Police Act.

The prosecution alleged that on 27.09.2010, the accused abused the complainant with caste-related derogatory words and threatened him after he objected to the accused’s children sitting in an open plot opposite his house.

The trial court acquitted the accused on the grounds that the prosecution failed to prove the case beyond reasonable doubt, noting contradictions in witness testimonies and the absence of independent witnesses.

1. Whether the trial court erred in its appreciation of evidence by giving undue weight to contradictions and omissions.

2. Whether the prosecution proved the charges under the IPC and the SC/ST (Prevention of Atrocities) Act beyond reasonable doubt.

3. Whether the appellate court should interfere with an order of acquittal when a plausible view has been taken by the trial court.

The Court applied the standard of "proof beyond reasonable doubt" in criminal jurisprudence.

It relied on the principle from Sajan Sakhariya v. State of Kerala (2024), establishing that insult or intimidation under Section 3(1)(x) of the SC/ST Act must be specifically directed at a victim because of their caste identity.

Regarding appellate powers in acquittal cases, the court followed Chandrappa v. State of Karnataka (2007) and Constable 907 Surendra Singh v. State of Uttarakhand (2025), which mandate a "double presumption of innocence" for the acquitted and restrict interference unless the trial court’s judgment is "patently perverse" or based on a misreading of evidence.

The Court found the prosecution's case fundamentally weak as key panch witnesses (PW-1, PW-2, PW-3) turned hostile, failing to prove the recovery of weapons or the authenticity of the scene-of-offence panchnama.

The Court observed that despite the incident occurring in a residential area with multiple communities present, the Investigating Officer failed to record statements from independent neighbors, relying solely on "interested witnesses" who were relatives of the complainant.

Furthermore, the complainant's credibility was questioned due to a history of filing multiple unsuccessful atrocity cases against the accused's family and an unexplained delay of one day in lodging the FIR.

Applying Sajan Sakhariya, the court noted that the prosecution failed to prove the insults were motivated strictly by the complainant's caste.

The court held that the trial court’s findings were reasonable and not perverse.

Since the prosecution failed to provide "substantial and compelling reasons" or demonstrate a manifest illegality to displace the double presumption of innocence, the appellate court declined to interfere with the lower court's decision.

The Record and Proceedings were ordered to be remitted to the trial court.