Prayagraj: In a significant judgment addressing the misuse of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989, the Allahabad High Court has imposed a fine of ₹5 lakh on 19 accused individuals and directed three women belonging to the Scheduled Caste community to refund ₹4.5 lakh they had received as compensation. The court termed the case a “gross misuse of the benevolent provisions” of the SC/ST Act and a “fraud upon the State,” observing that both the accused and the alleged victims had manipulated the judicial process.
The judgment was delivered by Justice Shekhar Kumar Yadav, who was hearing a criminal appeal filed by the 19 accused under Section 14-A(1) of the SC/ST Act. The appeal sought to quash the cognizance and summoning order issued by the Special Judge (SC/ST Act), Prayagraj, in a case registered under several sections of the Indian Penal Code — 147, 148, 149, 323, 504, 506, 452, and 354(kha) — as well as Section 3(2)(va) of the SC/ST Act.
During the hearing, the counsel representing the appellants claimed that the first information report (FIR) in the case had been lodged on the thumb impression of the complainant, implying that the complaint may have been fabricated or unauthorized. However, this contention was vehemently denied by the counsel for the complainant, who asserted that no such FIR had been filed by the victim.
Amid these contradictory claims, the Court took note of the fact that the complainant was a Dalit woman and suspected that she might have been influenced or pressured by the accused to alter her stand. Consequently, Justice Yadav summoned the Deputy Commissioner of Police (Yamunapar), the Investigating Officer, and the complainant to appear personally before the Court on November 6, 2025.
When all parties appeared as directed, the complainant made a startling revelation — she stated before the Bench that her thumb impression had been taken on a blank piece of paper. This statement cast serious doubt on the authenticity of the initial complaint. However, the Government Advocate (GA) countered this by producing the original case records, which showed that the FIR had indeed been lodged on the basis of a written complaint signed and submitted by the complainant herself.
The GA further informed the Court that the complainant and her two daughters-in-law had provided statements under both Sections 161 and 164 of the Code of Criminal Procedure (CrPC), in which all three had consistently supported the prosecution’s version of events. The women had also undergone medical examination and had each received ₹1.5 lakh as compensation from the State under the statutory relief scheme, totaling ₹4.5 lakh.
The Court expressed strong disapproval of the complainant’s subsequent denial of having filed the FIR, particularly since she had already availed herself of financial compensation and confirmed the allegations earlier under oath. Justice Yadav remarked that the victim’s reversal of her stand represented “a serious abuse of the process of law and a gross misuse of the benevolent provisions of the SC/ST Act.”
The order stated, “The Court finds it deeply disturbing that the complainant now denies having filed the FIR, despite having made statements under Section 164 Cr.P.C. affirming the allegations and having availed of substantial monetary compensation under the statutory scheme meant for genuine victims of atrocities.”
Calling the entire episode “a deliberate attempt to manipulate the criminal justice process after wrongfully obtaining public funds,” the Court described it as “a fraud upon the State.”
In light of these findings, the Court dismissed the appeal filed by the 19 accused and issued a set of firm directions. It ordered the complainant and her two daughters-in-law to jointly and severally refund the entire compensation amount of ₹4.5 lakh to the competent authority of the State Government without delay. Additionally, the bench imposed a fine of ₹5 lakh on the 19 accused for their role in manipulating the complainant and attempting to subvert justice. The amount is to be deposited in the High Court Welfare Fund within twenty days, failing which the Registrar General has been instructed to initiate coercive recovery proceedings.
While taking a stern view of the misuse of the SC/ST Act in this instance, the Court also clarified that its observations would not influence the ongoing criminal trial. The Special Judge (SC/ST Act), Prayagraj, has been directed to continue the proceedings strictly in accordance with law and unaffected by the contradictory stand taken by the complainant or the remarks made by the High Court.
