Mere verbal altercations without proof of targeted caste-based intent do not constitute offenses under the SC/ST Act.

The appellant/complainant, a cab driver, alleged that on January 22, 2019, respondent No. 2 (the accused) disrupted the taxi queue at a stand and, upon being challenged, physically assaulted him and uttered casteist slurs (e.g., "you are supposed to clean the streets and not to drive the car") knowing the appellant belonged to a Scheduled Caste

A trial was conducted under the IPC and the SC/ST Act, but the Trial Court acquitted the accused on June 20, 2024, citing the prosecution's failure to prove the case beyond reasonable doubt

The appellant challenged this acquittal before the Gujarat High Court

1. Whether the Trial Court erred in its appreciation of evidence by ignoring material facts and giving undue weight to minor contradictions

2. Whether the prosecution established the ingredients of an offense under Section 3(1)(r)(s) and 3(2)(5-A) of the SC/ST Act regarding insults in public view

Sections 323, 504, and 506(1) of the Indian Penal Code and Sections 3(1)(r)(s) and 3(2)(5-a) of the Scheduled Castes and the Scheduled Tribes (Prevention of Atrocities) Act

Sajan Sakhariya v. State of Kerala, establishing that every insult does not constitute an offense under the SC/ST Act unless motivated by the victim's caste identity

Chandrappa v. State of Karnataka and Ram Kumar v. State of Haryana, which mandate that if the Trial Court’s view is "reasonable and plausible," the appellate court should not disturb the acquittal even if a different view is possible.

The High Court found that the prosecution's case lacked corroboration from independent witnesses, as several panch witnesses (PW-3, PW-4, PW-5, PW-6) and a purported eyewitness (PW-8) turned hostile

Medical evidence from PW-1 and PW-2 indicated that the complainant’s injuries were either simple abrasions or subjective complaints (chest pain) with no external trauma, suggesting they could be self-inflicted

Crucially, the Investigating Officer (PW-13) and the officer who recorded the FIR (PW-10) admitted that specific caste-based slurs were not recorded in the initial statements

The court reasoned that since the place of the incident was a busy public area and no independent witness supported the allegations of casteist remarks, the double presumption of innocence in favor of the accused was strengthened

The court reaffirmed that in the absence of evidence showing the insult was directed specifically at the appellant's caste identity, the special provisions of the SC/ST Act are not attracted. Standard R&P were ordered to be remitted to the trial court