Offence under Sections 3(1)(r) and 3(1)(s) of SC/ST Act requires incident occur in "place within public view."

The Appellants (accused) and Respondent No. 2 (complainant) are family members involved in a property dispute

Appellant Nos. 1 and 4 are wives of respondent No. 2’s brothers; they do not belong to a Scheduled Caste (SC), whereas their husbands and the complainant do

The complainant alleged that on January 28, 2021, Appellant No. 1 hurled caste-based slurs (e.g., chura, chamar) at him and his wife while the other appellants issued threats

The incident allegedly occurred at their residential house in Ramesh Nagar

Following an FIR and investigation, the Trial Court framed charges under Sections 3(1)(r) and 3(1)(s) of the SC/ST Act against Appellant No. 1, and under Section 506 r/w 34 of the IPC against all appellants

The High Court of Delhi dismissed the appellants’ revision petition

1. Whether the alleged casteist abuses were uttered in a "place within public view" as required to constitute an offence under Sections 3(1)(r) and 3(1)(s) of the SC/ST Act

2. Whether the allegations in the FIR and charge-sheet satisfy the ingredients of "criminal intimidation" under Section 506 read with Section 34 of the IPC

The Court applied Sections 3(1)(r) and 3(1)(s) of the SC/ST Act, which require that insults or abuses against a member of an SC/ST must occur in a "place within public view"

It relied on the precedent in Swaran Singh v. State (2008), distinguishing a "public place" from a "place within public view," noting that even a private residence could be considered "within public view" if the act is visible/audible to the public (excluding relatives or friends)

The Court further applied Hitesh Verma v. State of Uttarakhand (2020) and Karuppudayar v. State (2025), which held that offences occurring within the four walls of a building where no public members are present do not meet the statutory requirement

For the IPC charges, the Court applied Sections 503 and 506, emphasizing that the "intent to cause alarm" is a pivotal ingredient for criminal intimidation

The Court observed that the FIR and charge-sheet explicitly identified the place of occurrence as a private residential house

Applying the "public view" test, the Court found that the incident took place within the four walls of the house among family members

The Court highlighted that for an act in a private space to be "within public view," it must be exposed to the "public gaze" or "public eye," which was absent here as the named witnesses were merely friends of the complainant and not independent members of the public who witnessed the occurrence

Regarding Section 506 IPC, the Court found the allegations failed to demonstrate an "intent to cause alarm," noting a lack of evidence that the appellants acted with a common intention to commit a criminal act under Section 34 IPC

It further held that subjecting the appellants to trial for Section 506/34 IPC would be an abuse of the process of law

Consequently, the Supreme Court set aside the High Court's judgment and the Trial Court's framing of charges, quashing FIR No. 42 of 2021 and the subsequent charge-sheet