Compensation under SC/ST Act is not maintainable once the underlying criminal proceedings are quashed.

The wife of the petitioner's brother (deceased Rakesh) allegedly had an illicit relationship with one Samarjeet Yadav; aggrieved thereby, the deceased committed suicide by drowning.

Crime No. 198 of 2019 was registered at Police Station Pichhore, District Gwalior, against the deceased's wife (Sangeeta) and Samarjeet Yadav for offences under Sections 306 and 34 IPC and Section 3(2)(v) of the SC/ST (Prevention of Atrocities) Act, 1989.

A charge-sheet was filed and charges were framed by the trial court; however, during pendency of trial, the accused sought quashing under Section 482 Cr.P.C., and this Court, vide order dated 04.01.2023 in M.Cr.C. No. 7331 of 2022, quashed the FIR, charge-sheet, and all consequential criminal proceedings.

The petitioner—real brother of the deceased—claimed statutory compensation of Rs. 8,50,000/- on the ground that the case was registered under the SC/ST Act.

The Commissioner, Scheduled Caste Development, Bhopal rejected the claim vide order dated 22.10.2025.

The petitioner thereafter approached this Court under Article 226 seeking a direction for release of the compensation amount, litigation costs, and consequential relief.

1. Whether the petitioner is entitled to statutory compensation under the SC/ST (Prevention of Atrocities) Act, 1989 and the Rules framed thereunder, once the underlying FIR, charge-sheet, and all consequential criminal proceedings have been quashed by this Court.

Rule 12 of the SC/ST (Prevention of Atrocities) Rules, 1995: while the core object of compensation is rehabilitation of victims of atrocities, the entitlement is neither automatic nor mechanical and is intrinsically linked to the commission or prima facie establishment of an offence under the Act.

Section 3(2)(v) of the SC/ST Act, which imposes a mandatory statutory requirement that the offence must have been committed against the victim specifically on the ground of caste identity.

A writ of mandamus under Article 226 of the Constitution can issue only where the petitioner establishes a clear, existing legal right and a corresponding legal obligation on the State.

Since compensation is contingent upon a prima facie established atrocity, the judicial quashing of the entire criminal prosecution arising out of Crime No. 198/2019—an order that attained finality—destroyed the very foundation of the claim, which thereafter ceased to exist in the eye of law.

There was no material on record even remotely suggesting caste-based malice or motive behind the alleged offence, thereby failing the mandatory statutory prerequisite of Section 3(2)(v).

In the absence of any subsisting criminal proceeding or finding of atrocity, the petitioner failed to demonstrate a legally enforceable right or corresponding duty on the State; consequently, the Commissioner’s rejection order dated 22.10.2025 suffered from no illegality, arbitrariness, or jurisdictional error.

The rejection order dated 22.10.2025 passed by the Commissioner, Scheduled Caste Development, Madhya Pradesh (Bhopal), was upheld as legal and sustainable and the writ petition was dismissed.