SC/ST Act conviction requires specific proof that insults were targeted at the victim's protected caste identity.

The State of Gujarat appealed a judgment dated 24.01.2013 by the Special Judge (Atrocity), Mehsana, which acquitted the respondents of charges under Sections 323, 504, and 114 of the Indian Penal Code (IPC), Section 3(1)(x) of the Scheduled Castes and the Scheduled Tribes (Prevention of Atrocities) Act ("SC/ST Act"), and Section 135 of the Bombay Police Act

The prosecution alleged that on 02.04.2010, the accused assaulted the complainant with sticks at a public vegetable market in Village Palli due to a grudge over a financial dispute involving Rs. 16,700

It was further alleged that the accused humiliated the complainant by insulting his caste in public

The trial court acquitted the accused, holding that the prosecution failed to prove the case beyond reasonable doubt

1. Whether the trial court erred in its appreciation of evidence by giving undue emphasis to contradictions and omissions

2. Whether the alleged insults and intimidation were directed at the complainant specifically because of his caste to attract liability under Section 3(1)(x) of the SC/ST Act

3. Whether the High Court, in an appeal against acquittal, should interfere with the trial court's findings if they represent a "possible" and "reasonable" view

The Court primarily applied Section 3(1)(x) of the SC/ST Act, 1989, alongside Sections 323 and 504 of the IPC.

It relied on Sajan Sakhariya v. State of Kerala (AIR 2024 SC 4557), which clarifies that an insult only constitutes an offence under the SC/ST Act if it targets the victim specifically due to their caste status

Regarding the scope of appellate interference in acquittals under Section 378 of the CrPC, the Court followed Chandrappa v. State of Karnataka [(2007) 4 SCC 415] and Constable 907 Surendra Singh v. State of Uttarakhand [(2025) 5 SCC 433], which mandate that the "double presumption of innocence" must be respected unless the trial court’s judgment is patently perverse or suffers from a misreading of material evidence

The Court found that the prosecution's case rested on the testimony of the complainant and his immediate family, who were deemed interested witnesses

Despite the incident occurring in a public square near a temple, dairy, and shops where 20-25 people had gathered, the prosecution failed to examine any independent witnesses

Medical evidence through P.W.4 and Exh. 23 confirmed the absence of fractures, weakening the assault claim

Furthermore, the Court noted significant contradictions regarding the alleged caste-based abuse and observed that the dispute was rooted in financial accounting rather than caste animus

Applying the principles of Chandrappa, the Court reasoned that since the trial court's view was plausible and based on a detailed analysis of the lack of corroborating evidence, there was no ground to substitute it with a different opinion

It held that the prosecution failed to prove the charges beyond reasonable doubt and that the trial court’s findings were neither perverse nor illegal

The Court endorsed the trial court’s reasoning that every insult does not amount to an atrocity under the SC/ST Act unless motivated by the victim's caste

The Record & Proceedings were ordered to be remitted to the trial court