Land dispute motive and inconsistent witness testimony negate charges under the SC/ST (POA) Act.

The appellant (complainant) filed a complaint, later converted into Chainpur P.S. Case No. 104 of 2019, alleging that on 05.11.2018, Respondent Nos. 2 and 3 (the accused) abused him using caste-based slurs and assaulted him with fists and slaps at a Block office

The appellant further alleged a long-standing land dispute regarding 14 decimals of land allotted to his grandfather, claiming the respondents had grabbed 58 decimals of land and frequently threatened his family

Following a trial involving nine prosecution witnesses, the Special Judge, SC/ST (POA) Act, Palamau, acquitted the respondents of all charges via judgment dated 13.09.2024

1. Whether the Trial Court erred in acquitting the respondents for charges under Sections 504 and 506 of the IPC and Sections 3(1)(g), 3(1)(r), and 3(1)(s) of the SC/ST (POA) Act

2. Whether the prosecution evidence was sufficient to establish that the alleged assault and verbal abuse were motivated by the victim's caste identity rather than a bona fide land dispute

The Court applied the evidentiary standards for criminal conviction under Sections 504 (Intentional insult with intent to provoke breach of the peace) and 506 (Criminal intimidation) of the Indian Penal Code, and the specific protections against land dispossession and public humiliation under Sections 3(1)(g), (r), and (s) of the Scheduled Castes and the Scheduled Tribes (Prevention of Atrocities) Act

The court relied on the principle that evaluation of evidence is the primary domain of the trial court and that an order of acquittal should not be interfered with unless it is perverse or the evidence is misapplied

The Court observed that the prosecution’s case was weakened by significant inconsistencies and improvements in witness testimonies. While P.W.1 and P.W.2 testified to an altercation, they denied witnessing any assault; P.W.3 (the informant) admitted the incident occurred without witnesses and stemmed from a persistent land dispute

The Court noted that P.W.4 and P.W.6 admitted to providing hearsay evidence or facts not previously stated to the police

The Investigating Officer’s testimony further highlighted that the witnesses’ court depositions deviated significantly from their original statements

The High Court upheld the Trial Court’s findings that the altercation was a result of a bona fide land dispute (including a pending Title Suit No. 148 of 2020) rather than caste-based malice, and that the prosecution witnesses had significantly improved upon the story to fit the rigors of the SC/ST Act

It held that the prosecution failed to prove the charges beyond a reasonable doubt, as the evidence was inconsistent and the underlying motive for the conflict was a civil land dispute rather than the appellant's caste

The court found no legal grounds to interfere with the Trial Court’s evaluation of the evidence