SC/ST Act caste-abuse offences require intentional humiliation in a place within public view.

The complainant, who belongs to a Scheduled Caste, alleged that the respondents quarrelled with his relatives at agricultural land on 3 July 2016, used caste-related abuse, threatened them and set fire to the field’s fencing.

He further alleged that on 14 July 2016 the respondents threatened his family, damaged crops, and one respondent struck a relative with a stick.

The complainant lodged the FIR on 20 July 2016.

The trial court acquitted the respondents of offences under Sections 143, 323, 504, 506(2) and 435 of the IPC and Section 3(1)(r) and (s) of the SC/ST (Prevention of Atrocities) Act, 1989.

The complainant appealed under Section 378 CrPC.

Whether the trial court’s acquittal was affected by an error warranting appellate interference under Section 378 CrPC

Whether the prosecution proved the ingredients of the alleged offences under Section 3(1)(r) and (s) of the SC/ST Act, including that the alleged caste-based insult occurred within public view

Section 378 CrPC permits an appellate court to review and reappreciate evidence in an appeal against acquittal; however, the accused benefit from a double presumption of innocence, and where two reasonable views are possible, the acquittal should not be disturbed

For an offence under Section 3(1)(r) or (s) of the SC/ST Act, the prosecution must establish intentional insult or intimidation to humiliate a Scheduled Caste or Scheduled Tribe person, including the statutory requirement that it occur in a place within public view

The judgment also referred to *Ramesh v. State of Karnataka*, (2024) 9 SCC 169, and *Karuppudayar v. State*, 2025 AIR (SC) 705

The High Court found no basis to overturn the acquittal.

The scene-of-offence panchnama did not support the allegation that the fencing had been burned, and the FIR was lodged about seventeen days after the alleged 3 July incident

The prosecution had not proved the central allegations through cogent evidence; the complainant’s family were not legal owners or occupiers of the government land, and their allotment application remained pending

As to the SC/ST Act charges, the alleged incident occurred in an agricultural field, and the court found the required public-view ingredient unproved

Applying the principles governing appeals against acquittal, the court concluded that the trial court’s assessment was not perverse or legally erroneous and that the evidence did not compel a contrary conclusion

The appeal was dismissed, the trial court’s acquittal was confirmed, the bail bond was cancelled, and the record and proceedings were directed to be returned to the trial court