Misuse of supervisory authority by teacher to commit sexual assault during school camp precludes grant of anticipatory bail.

The appellant, a school teacher and sports in-charge, sought anticipatory bail following the dismissal of his application (B.A. No. 21/2026) by the Special Judge, SC/ST Act, Janjgir-Champa.

The prosecution alleges that during an NSS camp in December 2025, the appellant lured a 12th-grade student into a bathroom under the pretext of checking water availability, gagged her, and attempted to outrage her modesty.

The incident was interrupted by a friend of the victim.

The appellant claims false implication due to previous enmity.

The victim belongs to a Scheduled Caste community.

Whether the appellant is entitled to the protection of anticipatory bail under Section 14A(2) of the SC/ST (Prevention of Atrocities) Act in light of the gravity of the allegations.

Whether the fiduciary relationship between a teacher and a student, combined with the nature of the alleged assault, necessitates custodial interrogation or dismissal of bail.

The Court applied the provisions of the Bharatiya Nyaya Sanhita (BNS), specifically Sections 64(2)(f) (rape by a person in a position of trust or authority), 62 (attempt to commit an offence), 74 (assault or use of criminal force to woman with intent to outrage her modesty), and 351(2) (criminal intimidation).

Furthermore, it applied Sections 3(2)(v) and 3(2)(v-a) of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989, which provides enhanced penalties for offences committed against members of SC/ST communities.

Procedurally, the court considered the victim's statement recorded under Section 183 of the Bharatiya Nagarik Suraksha Sanhita (BNSS).

The Court observed that the appellant held a position of "official position and authority" as the school's sports in-charge, being entrusted with the safety of 60–65 students during an out-of-station camp.

It noted that the appellant allegedly used a deceptive pretext to isolate the victim in a secluded space (a bathroom), which constitutes a grave misuse of his fiduciary role.

The Court scrutinized the victim’s Section 183 BNSS statement, which detailed not only the specific instance of assault but also a "continuing pattern of misconduct" and prior intimidation.

The Court determined that such "grave" circumstances and the risk of witness intimidation (threats of dire consequences) outweighed the appellant’s plea of false implication.

The High Court affirmed the trial court's order and rejected the criminal appeal for anticipatory bail filed by Sanjay Kumar Yadav.