SC/ST Act Charge Set Aside: Supreme Court Grants Benefit of Doubt in Caste Abuse Case

The case of Narad Patel vs. State of Chhattisgarh revolves around the conviction of the appellant under Section 294 of the Indian Penal Code (IPC) and Section 3(1)(x) of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989. The Supreme Court granted the appellant the benefit of doubt regarding the SC/ST Act charge while upholding the conviction under Section 294 IPC.

The appellant was initially convicted by the Special Judge, Raigarh, Chhattisgarh, for allegedly hurling caste-based abuses at the complainant, Deshiram, during a Panchayat meeting. The High Court of Chhattisgarh upheld the conviction. However, the Supreme Court found inconsistencies in the testimony regarding caste-based remarks and granted the appellant relief under the SC/ST Act.

Background of the Case

The incident occurred on the night between September 30, 2001, and October 1, 2001, when the appellant allegedly cut the boundary hedge (medh) of complainant Deshiram’s paddy field, causing water to drain out. The next day, a Panchayat was called, where the appellant reportedly abused Deshiram and his brother Shyam Sunder, issuing threats and using caste-related slurs.

The prosecution charged the appellant under Sections 294 and 506-B IPC and Section 3(1)(x) of the SC/ST Act. The trial court found him guilty under Section 294 IPC and Section 3(1)(x) of the SC/ST Act but acquitted him of the Section 506 IPC charge.

Petitioner’s Arguments

The appellant, represented by Advocate Vikrant Singh Bais, argued:

• The allegations under the SC/ST Act were not supported by the complainant’s own testimony.
• While the complainant confirmed the verbal altercation, he did not mention any caste-based abuse in his deposition.
• Other prosecution witnesses made inconsistent statements regarding the alleged caste slurs.
• The appellant had already served over four months in prison, warranting a lenient view.
• Since the trial court had acquitted him of criminal intimidation (Section 506 IPC), the alleged threats were unsubstantiated.

Respondent’s Arguments

The State of Chhattisgarh, represented by Advocate Nizam Pasha, countered:

• The appellant had engaged in verbal abuse during a Panchayat meeting attended by multiple witnesses.
• Witnesses confirmed that the appellant had insulted the complainant in front of villagers.
• The SC/ST Act’s purpose is to prevent caste-based atrocities, and the presence of witnesses supported the complainant’s claims.
• The High Court had affirmed the trial court’s findings, and there was no need for further leniency.

Supreme Court’s Analysis

The Supreme Court examined whether the prosecution had sufficiently proven that the appellant’s abuse was caste-based. Key legal observations included:

• The complainant’s testimony did not confirm caste-based remarks, though some witnesses claimed otherwise.
• Convictions under the SC/ST Act require clear evidence that the abuse was directed specifically due to the victim’s caste.
• Since the complainant’s own statement lacked any reference to caste-related insults, the benefit of doubt was warranted.
• The conviction under Section 294 IPC, which penalizes obscene words in public, was justified based on undisputed verbal abuse.

Key Judicial Findings

The Supreme Court ruled:

• The conviction under Section 294 IPC was upheld, affirming a three-month rigorous imprisonment sentence.
• The conviction under Section 3(1)(x) of the SC/ST Act was set aside due to insufficient evidence.
• The appellant was granted the benefit of doubt regarding the caste-based abuse allegations.
• The appellant was ordered to be released unless required in connection with any other case.

Conclusion and Impact

The Supreme Court’s ruling highlights the importance of clear and unambiguous evidence in cases under the SC/ST Act. While the judgment upholds punishment for public verbal abuse, it also reinforces the principle that allegations under special laws require strict proof.

This decision serves as a precedent for cases where inconsistent testimony creates doubts about caste-based offenses, ensuring a balance between protecting SC/ST individuals and preventing misuse of legal provisions.

Petitioner Name: Narad Patel.
Respondent Name: State of Chhattisgarh.
Judgment By: Justice Arun Mishra, Justice Uday Umesh Lalit.
Place Of Incident: Raigarh, Chhattisgarh.
Judgment Date: 10-05-2019.

Don’t miss out on the full details! Download the complete judgment in PDF format below and gain valuable insights instantly!

Download Judgment: Narad Patel vs State of Chhattisgar Supreme Court of India Judgment Dated 10-05-2019.pdf

Direct Downlaod Judgment: Direct downlaod this Judgment

See all petitions in SC/ST Act Case
See all petitions in Fraud and Forgery
See all petitions in Judgment by Arun Mishra
See all petitions in Judgment by Uday Umesh Lalit
See all petitions in partially allowed
See all petitions in Modified
See all petitions in supreme court of India judgments May 2019
See all petitions in 2019 judgments

See all posts in Criminal Cases Category
See all allowed petitions in Criminal Cases Category
See all Dismissed petitions in Criminal Cases Category
See all partially allowed petitions in Criminal Cases Category