'Caste Abuse Inside Closed Room Not 'Public View' Under SC/ST Act': SC

The Supreme Court has held that a caste-based insult made inside a closed room, without the presence of members of the public, does not by itself meet the “public view” requirement under the SC/ST (Prevention of Atrocities) Act. The ruling came while quashing proceedings against a school manager accused of abusing a complainant with casteist remarks.

A bench of Justices Vikram Nath and Sandeep Mehta was hearing an appeal against an Allahabad High Court order that had refused to interfere with the case registered under the SC/ST Act.

About The Case

The dispute arose after the complainant, whose two sons were students at the school, went to meet the school manager following a quarrel between students. The complainant alleged that the manager and school employees assaulted him and subjected him to caste-based abuse.

A police case was subsequently registered under the SC/ST Act and a chargesheet was filed. Separately, the manager's wife lodged a counter-FIR accusing the complainant of verbally abusing and assaulting her inside the school office. She claimed that when the manager stepped in, he too was attacked. A local court later took cognisance of the chargesheet in the counter-case.

The school manager challenged the summons issued by the special court before the Allahabad High Court. However, the high court declined to quash the proceedings, observing that allegations of personal vendetta alone were insufficient to establish that the case was malicious and finding a prima facie case against him.

Before the Supreme Court, the manager's counsel argued that the alleged casteist remarks were made inside a closed room. Witness statements, the lawyer said, did not indicate that members of the public were present inside or that anyone outside the room had heard the alleged remarks.

The Supreme Court examined the requirements under Sections 3(1)(r) and 3(1)(s) of the SC/ST Act, which cover intentional insult or intimidation and caste-based abuse when committed in a place within public view.

The bench reiterated that an incident can fall within “public view” when members of the public are present at the location and are able to see or hear the alleged conduct. However, an incident taking place inside a confined space, with no members of the public present, cannot automatically be treated as occurring in public view.

The court also noted that the witness statements did not substantiate the allegation of casteist abuse. While teachers confirmed that a dispute and physical altercation had taken place, none of them stated that they had witnessed or heard the alleged caste-based remarks.

On these grounds, the Supreme Court set aside the proceedings against the school manager under the relevant provisions of the SC/ST Act. However, it clarified that proceedings relating to other offences registered under the Indian Penal Code would continue.