SC/ST Act and IPC 504 charges require specific abusive language and occurrence within public view.

The applicants sought the quashing of an FIR registered under Sections 504, 506(2), and 114 of the IPC, and Sections 3(1)(r), 3(1)(s), and 3(2)(va) of the Scheduled Castes and the Scheduled Tribes (Prevention of Atrocities) Act, 1989

The complainant alleged that the applicants, who own adjoining land, were using his field as a pathway.

On March 8, 2022, when the complainant objected, the applicants allegedly used caste-based slurs and threatened him with "dire consequences"

Despite these threats, the complainant dug up the pathway on March 9, 2022.

He later discovered on March 26, 2022, that the applicants had refilled it

The FIR was eventually lodged on April 1, 2022, following a delay of 22 days

1. Whether the allegations in the FIR satisfy the essential ingredients of Sections 504 and 506(2) of the IPC regarding intentional insult and criminal intimidation

2. Whether the alleged caste-based abuse occurred in "public view" as mandated by Sections 3(1)(r) and 3(1)(s) of the Atrocities Act

3. Whether the continuation of criminal proceedings constitutes an abuse of the process of law given the civil nature of the pathway dispute

The court applied Section 504 of the IPC, which requires an intentional insult likely to provoke a breach of public peace, and Section 506, which requires a threat intended to cause "alarm"

It relied on Om Prakash Ambadkar v. State of Maharashtra (2026), which established that mere abusive language without specific words or proof of intent to provoke a breach of peace is insufficient for conviction

Regarding the Atrocities Act, the court applied the "public view" requirement from Sections 3(1)(r) and 3(1)(s)

It further relied on Karuppudayar v. State (2025), which clarifies that "public view" implies a place where members of the public (excluding relatives or friends) can witness or hear the utterance, distinguishing it from a "public place"

The court observed that the FIR was filed after a 22-day delay and failed to specify the exact abusive words used, which is necessary to determine if an insult was "intentional" under Section 504 IPC

The court found that no "alarm" was caused to the complainant because he proceeded to dig up the pathway the very next day despite the alleged threats, thus failing the test for Section 506(2)

Regarding the Atrocities Act, the court noted the incident took place in a private field where the only witness was a person of the same caste as the complainant

Consequently, the requirement of the act occurring within "public view" was not met

The court characterized the matter as a civil dispute over a pathway being given a criminal color

The court concluded that allowing the criminal proceedings to continue would amount to an abuse of the process of law

Accordingly, the Court allowed the application and quashed FIR C.R. No. 11190002220710 of 2022 along with all consequential proceedings