Mere caste identity and property disputes do not establish Section 3(1)(x) without caste-based humiliation.

The appellant–complainant alleged that he, his mother and his brother were cultivating land bearing Survey No. 171/1, Block No. 283, over which a civil dispute was pending with respondent No. 2.

On 16 July 2007, while they went to the agricultural field, respondents Nos. 2 and 3 and other persons allegedly prevented them from entering, abused them, and assaulted them with fists and kicks.

The complainant claimed that the police initially refused to register his complaint, following which he sent a complaint by registered post and subsequently approached the Magistrate pursuant to directions issued by the High Court.

An FIR was thereafter registered, investigation was completed, and a charge-sheet was filed.

The accused were charged under Sections 147, 148, 323, 504 and 506(2) of the IPC and Section 3(1)(x) of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989.

The trial Court acquitted all the accused, principally finding that the prosecution evidence was unreliable and that the dispute arose from an agricultural-land dispute.

The complainant preferred an appeal under Section 372 CrPC against the acquittal.

Whether the prosecution proved beyond reasonable doubt that the respondents committed the alleged offences under Sections 147, 148, 323, 504 and 506(2) of the IPC?

Whether the prosecution established the ingredients of the erstwhile Section 3(1)(x) of the SC/ST Act, including intentional caste-based insult or intimidation in a place within public view?

Whether the High Court, in an appeal against acquittal filed by the complainant, should interfere with the trial Court’s findings when two reasonable views are possible on the evidence?

The Court considered Sections 147, 148, 323, 504 and 506(2) of the IPC and the erstwhile Section 3(1)(x) of the SC/ST Act.

Section 3(1)(x) required intentional insult or intimidation of a member of an SC/ST community with intent to humiliate in a place within public view, and the insult had to be connected with the victim’s caste identity rather than arising merely from a personal or property dispute.

Relying on Shajan Skaria v. State of Kerala, AIR 2024 SC 4557, and the principles in Hitesh Verma v. State of Uttarakhand and Ramesh Chandra Vaishya, the Court held that every insult to an SC/ST member does not attract the SC/ST Act unless it is motivated by the victim’s caste and constitutes caste-based humiliation.

In an appeal against acquittal, the appellate Court has power to reappreciate the evidence, but the accused benefit from a reinforced double presumption of innocence; where two reasonable conclusions are possible, the acquittal should not be disturbed.

This principle was drawn from Chandrappa v. State of Karnataka, (2007) 4 SCC 415, Rajesh Prasad v. State of Bihar, (2022) 3 SCC 471, Babu Sahebagouda Rudragoudar v. State of Karnataka, AIR 2024 SC 2252, and Ramesh v. State of Karnataka, (2024) 9 SCC 169.

The High Court found that the prosecution case was substantially supported only by interested witnesses and that no independent witness had corroborated the alleged incident, which occurred in an agricultural field rather than in a public place or public view.

The evidence regarding the alleged assault was not satisfactory or sufficiently credible to establish the IPC offences beyond reasonable doubt.

Further, the surrounding circumstances showed that the parties were engaged in a pre-existing dispute concerning possession and cultivation of the land.

The alleged abuses were therefore treated as arising from that property dispute, with no reliable evidence that the respondents insulted or intimidated the complainant because of his SC/ST identity or with an intention to cause caste-based humiliation.

On reappreciation, the High Court held that the trial Court’s view was a reasonable one and was neither perverse nor based on a manifest misreading of the evidence.

The enhanced restraint applicable in an appeal against acquittal therefore required confirmation of the trial Court’s judgment.

It held that the prosecution failed to prove the alleged IPC offences and the offence under Section 3(1)(x) of the SC/ST Act beyond reasonable doubt, and that the trial Court had committed no error in acquitting the respondents.

The appeal under Section 372 CrPC was dismissed, the judgment and order of acquittal dated 26 July 2011 in Atrocity Case No. 14 of 2010 were confirmed, the bail bonds were cancelled, and the record and proceedings were directed to be sent back to the trial Court.