Investigative powers conferred on Police Inspectors under Section 9(1) of the SC/ST Act supersede Rule 7 requirements.

The appellant challenged an order dated 26.11.2025 passed by the Special Judge (SC/ST Act), Dindori, which framed charges against him for stalking, assault, outraging modesty, criminal intimidation, and caste-based abuse under Sections 78(1)(i), 296, 351(3), 332(c), 74, and 75(1)(i) of the Bharatiya Nyaya Sanhita (BNS), 2023, and various sections of the SC/ST (Prevention of Atrocities) Act, 1989.

The prosecution alleged that on 13.09.2025, the appellant entered the victim's house, assaulted her, and used caste-based slurs.

The appellant argued the FIR was a "counterblast" to previous enmity and that the investigation was void as it was conducted by an officer below the rank of Deputy Superintendent of Police, allegedly violating Rule 7 of the SC/ST Rules, 1995.

1. Whether the investigation was vitiated due to non-compliance with Rule 7 of the SC/ST Rules regarding the rank of the investigating officer.

2. Whether the Trial Court erred in framing charges based on the material available on record.

3. Whether the plea of previous enmity and "public view" requirements can be adjudicated at the stage of framing of charge.

The court applied Section 14-A(1) of the SC/ST Act regarding appeals.

At the stage of framing charges, the court only needs to find "strong suspicion" and a prima facie case, rather than conducting a "mini-trial" or meticulous appreciation of evidence.

Section 9(1) of the SC/ST Act and State Government Notification dated 07.10.2017 empowered Police Inspectors to investigate such offences, overriding general objections regarding Rule 7 of the SC/ST Rules.

Precedents including Hitesh Verma v. State of Uttarakhand and State of M.P. v. Babbu Rathore were considered but distinguished based on the facts and the 2017 Notification.

The court reasoned that since the FIR was lodged within one hour of the incident and multiple witnesses (Lakshmi Bai, Prem Lal, etc.) supported the victim’s version during the investigation, there was sufficient prima facie material to frame charges.

The 2017 Notification issued under Section 9(1) of the Act legally authorized Police Inspectors to conduct investigations, thereby rendering the appellant's reliance on Rule 7 (requiring a DSP-level officer) meritless.

The court further observed that arguments concerning "previous enmity," "false implication," or whether the incident occurred in "public view" are matters of defense and evidence that must be tested during the trial, not at the preliminary stage of framing charges.

The High Court dismissed the appeal, affirming the Trial Court’s order to frame charges, clarifying that its observations were limited to the maintainability of the charges.