Bulandshahr: The Allahabad High Court has delivered a significant ruling on the application of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, observing that disputes of a purely civil nature should not be converted into criminal cases merely to settle personal scores. The court held that criminal proceedings cannot be used as a means of harassment or to exert pressure in private disputes, particularly where the essential ingredients required under the SC/ST Act are absent.
The judgment came while the High Court was hearing a criminal appeal filed by Lalit Kumar alias Lalit Arya, who had challenged a summons order and charge sheet issued against him by a Special SC/ST Court in Bulandshahr, Uttar Pradesh. Justice Santosh Rai, presiding over the matter, allowed the appeal and quashed both the summons order dated July 8, 2024, and the charge sheet, concluding that the case did not satisfy the legal requirements for prosecution under the SC/ST Act.
The case stemmed from a dispute over a shop situated near an Arya Samaj temple in Khurja, Bulandshahr. The complainant was a tenant occupying the shop, while Lalit Kumar served as the cashier of the temple. According to the complaint, on March 12, 2023, Lalit Kumar and several others allegedly visited the shop, assaulted the complainant and used caste-based derogatory remarks against him.
However, the FIR was lodged on April 9, 2024, more than a year after the alleged incident. Although the FIR initially named five individuals along with several unidentified persons, the police investigation ultimately resulted in a charge sheet being filed only against Lalit Kumar. Based on the charge sheet, the Special SC/ST Court issued summons, prompting the appellant to move to the Allahabad High Court.
During the proceedings, counsel for the appellant argued that the FIR had been filed after an unexplained delay of over one year and that the allegations were rooted in an ongoing tenancy dispute rather than any caste-based offence. The defence maintained that the criminal case was initiated to pressure the appellant in connection with the civil dispute over the rented property.
On the other hand, the State opposed the appeal, contending that the complainant’s statements and evidence collected during the investigation disclosed a prima facie case. It argued that the delay in filing the FIR or the removal of other accused persons from the charge sheet did not, by themselves, justify quashing the proceedings at the preliminary stage.
After examining the case records, the High Court observed that the prosecution had failed to provide a satisfactory explanation for the considerable delay in registering the FIR. The court also noted that a tenancy dispute between the parties had existed prior to the criminal complaint, indicating that the conflict was fundamentally civil in nature.
Referring to landmark Supreme Court judgments, including Swaran Singh v. State, Hitesh Verma v. State of Uttarakhand, and Inder Mohan Goswami v. State of Uttaranchal, the High Court reiterated the legal principles governing offences under Sections 3(1)(r) and 3(1)(s) of the SC/ST Act. It emphasized that these provisions apply only when the alleged act of insult or intimidation takes place in a location within public view and is intended solely to humiliate the victim because of their caste.
The court clarified that ordinary disputes arising out of civil relationships, including tenancy disagreements, cannot automatically attract the provisions of the SC/ST Act merely because allegations of caste-based abuse have been made. It cautioned that allowing such prosecutions without satisfying the statutory requirements would amount to an abuse of the criminal justice system.
In its observations, the High Court remarked that criminal law should not become a tool for settling personal grievances or gaining leverage in civil litigation. The judgment underscored that criminal proceedings initiated with the objective of exerting pressure in a civil dispute undermine the integrity of the legal process.
Finding that the essential ingredients required for invoking the SC/ST Act were not established even on a prima facie basis, the court concluded that continuing the prosecution would constitute a misuse of legal provisions. Accordingly, it allowed the appeal and set aside the summons order and charge sheet issued by the Special SC/ST Court.
