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

The complainant alleged that on 14 September 2016, the accused used caste-related derogatory language and behaved vulgarly, including allegedly removing his pants, in the presence of the complainant’s family.

An FIR was registered under Sections 354A, 294B and 506(2) of the IPC and Sections 3(1)(r), 3(1)(s) and 3(2)(5-A) of the SC/ST (Prevention of Atrocities) Act.

After trial, the Special Court acquitted the accused on 27 August 2018.

The State appealed under Section 378 CrPC.

Whether the trial court was justified in acquitting the accused

Whether the trial court properly appreciated the prosecution evidence and whether its acquittal judgment disclosed any illegality, irregularity or perversity warranting appellate interference

Sections 3(1)(r) and 3(1)(s) of the SC/ST Act require proof of the statutory ingredients of intentional insult or intimidation to humiliate a member of an SC/ST community, including the relevant requirement that the conduct occur within public view, as discussed in Gunjan alias Girija Kumari v. State (NCT of Delhi), 2026 INSC 468.

The Court also referred to Sections 354A and 294B IPC and the prosecution’s obligation to establish the charged offences through satisfactory evidence.

On an appeal against acquittal, the appellate court may review and reappreciate the evidence, but must account for the reinforced presumption of innocence; where two reasonable views are possible, it should not disturb the acquittal.

These principles were drawn from Chandrappa v. State of Karnataka, (2007) 4 SCC 415, Rajesh Prasad v. State of Bihar, (2022) 3 SCC 471, Babu Sahebagouda Rudragoudar v. State of Karnataka, (2024) 8 SCC 149, and Ramesh v. State of Karnataka, (2024) 9 SCC 169.

The Court found that the complainant had not specified the alleged caste-related words or shown that they were used with the required intent to insult or humiliate; the public-view ingredient was also not established.

The allegations of vulgar conduct and offences under Sections 354A and 294B IPC were unsupported by satisfactory evidence: the complainant’s family members had gone inside during the altercation and could not see whether the accused removed his pants or acted indecently.

The Court also noted the FIR omissions, the investigating officer’s failure to examine neighbouring occupants, and evidence of a parking dispute between the parties.

Applying the restraint required in an appeal against acquittal, it concluded that the trial court’s assessment was not perverse or legally erroneous.

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