Supreme Court Sets Aside High Court Order on SC/ST Act Case, Clarifies Cognizance Procedure

The Supreme Court of India recently delivered a significant judgment in the case of Pramila Devi & Ors. vs. The State of Jharkhand & Anr., addressing critical legal questions surrounding the procedure for taking cognizance in criminal cases, particularly those involving the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989 (SC/ST Act). The judgment, authored by Justice Ahsanuddin Amanullah, overturned the Jharkhand High Court’s order remanding the matter for fresh consideration and clarified the legal standards for cognizance under criminal law.

The case arose from a dispute between Pramila Devi (the first wife of Vishnu Sahu) and Jyoti Beck (the second wife), who alleged that Vishnu Sahu and his family had deceived her into marriage, misused her property, and subjected her to harassment under the SC/ST Act. The appellants challenged the High Court’s decision to set aside the cognizance order, arguing that the FIR was filed with mala fide intentions and lacked prima facie evidence.

The Supreme Court’s judgment focused on two key issues: (1) whether a magistrate must record detailed reasons while taking cognizance, and (2) whether the FIR was filed with mala fide intent, warranting its quashing. The Court relied on several precedents, including Bhushan Kumar v. State (NCT of Delhi), to reiterate that a magistrate is not required to provide elaborate reasoning at the cognizance stage. The Court observed:

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“Time and again it has been stated by this Court that the summoning order under Section 204 of the Code requires no explicit reasons to be stated because it is imperative that the Magistrate must have taken notice of the accusations and applied his mind to the allegations made in the police report and the materials filed therewith.”

The appellants contended that the FIR was an abuse of process, filed 26 years after the alleged marriage, and that the dispute was essentially civil in nature. However, the Court noted that the chargesheet contained sufficient material to proceed with the trial, and the veracity of the allegations could only be tested during the trial. The judgment emphasized:

“The concerned Court is not empowered to go into the veracity of the material at that time. That is why, the law provides for a trial where it is open to both the parties… to lead evidence(s) either to prove the materials which have come against the accused or to disprove such findings.”

Ultimately, the Supreme Court set aside the High Court’s order and restored the cognizance taken by the Additional Judicial Commissioner, allowing the trial to proceed. The judgment reinforces the principle that magistrates need not provide detailed reasoning at the cognizance stage and underscores the importance of allowing criminal proceedings to run their course when prima facie material exists.

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Petitioner Name: Pramila Devi & Ors..
Respondent Name: The State of Jharkhand & Anr..
Judgment By: Justice Sudhanshu Dhulia, Justice Ahsanuddin Amanullah.
Place Of Incident: Ranchi, Jharkhand.
Judgment Date: 23-04-2025.
Result: allowed.

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