Supreme Court Acquits Accused in SC/ST Act Case Citing Inconsistent Evidence and Lack of Public View
In a significant judgment delivered on April 7, 2025, the Supreme Court of India acquitted several accused persons in a case involving allegations under the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989 (SC/ST Act) and Section 447 of the Indian Penal Code (IPC). The case, titled Hutu Ansari @ Futu Ansar & Ors. vs The State of Jharkhand, highlights crucial aspects of evidence evaluation in cases involving caste-based allegations and the importance of establishing offenses beyond reasonable doubt.
Detailed Case Background
The case originated from a land dispute in Lohardaga, Jharkhand, involving:
- A 28-decimal land parcel (Khata No. 116 Plot No. 698)
- Previous litigation settled through Ext. 5 on 25.04.2005
- Alleged incident on 22.05.2005 at 7 am
- Complaint filed under Section 156(3) CrPC (Complaint Case No. 58/2005)
The prosecution alleged that:
- Accused trespassed into complainant’s house/land
- Used caste-based derogatory terms
- Stole household items worth ₹3,000
- Threatened and humiliated the complainants
Detailed Trial Proceedings
The case saw multiple stages of adjudication:
| Court | Decision | Sentence |
|---|---|---|
| Trial Court | Convicted all 9 accused | 3 months SI (IPC), 2 years SI (SC/ST Act) |
| High Court | Confirmed conviction | Enhanced to 6 months (SC/ST Act), 3 months (IPC) |
| Supreme Court | Acquitted appellants | Set aside all convictions |
Key Arguments Before Supreme Court
Appellants’ Submissions (Verbatim)
Mr. Braj Kishore Mishra, counsel for appellants argued:
“The case was foisted due to land dispute enmity…all prosecution witnesses are related…no independent witnesses…offenses under SC/ST Act not made out as alleged abuses not in public view.”
Key defense points:
- Land dispute history since 2005
- All witnesses were family members
- No public present during alleged incident
- Inconsistencies between complaint and evidence
State’s Counter-Arguments (Verbatim)
Mr. Vishnu Sharma, standing counsel for Jharkhand submitted:
“Trial court and High Court concurrently found accused guilty…caste abuses were proved…trespass established…no reason to interfere.”
Prosecution’s case rested on:
- Complaint allegations
- Witness testimonies
- Previous land dispute records
- Presumption under SC/ST Act
Supreme Court’s Detailed Analysis
1. Evaluation of Evidence
The Court meticulously examined witness statements:
“PW-1 categorically stated no villagers present during incident…PW-2 gave different version of abuses…PW-3’s testimony inconsistent with complaint…PW-4 mentioned different caste term…PW-6 didn’t support occurrence.”
Key evidentiary flaws identified:
- Place of occurrence differed between complaint (house) and evidence (field)
- No corroboration for theft allegations
- Varying accounts of caste-based abuses
- No independent witnesses
2. Application of SC/ST Act Provisions
The Court analyzed Section 3(1) clauses:
| Clause | Requirement | Court’s Finding |
|---|---|---|
| (f) | Wrongful land occupation | No evidence of forceful eviction post 25.04.2005 settlement |
| (r) | Intentional insult in public view | No public present as per PW-1 |
| (s) | Caste abuse in public view | Same as (r) – no public view established |
3. Trespass Evaluation
The Court noted:
“Complaint alleged house lock breaking but witnesses spoke of field incident…no evidence supports house trespass…contradictions fatal to prosecution case.”
Landmark Observations
The judgment made several significant observations:
- On Public View Requirement: “Abuses not in public view cannot attract Section 3(r) or (s)”
- On Witness Reliability: “Related witnesses’ inconsistent testimonies create reasonable doubt”
- On Land Dispute Context: “Previous litigation history relevant in evaluating motives”
- On Burden of Proof: “Presumptions under SC/ST Act don’t relieve prosecution of basic burden”
Final Judgment and Directions
The Supreme Court concluded:
“Gross inconsistencies between complaint and evidence…no offense under SC/ST Act made out…trespass not proved…convictions unsustainable.”
Specific directions included:
- Acquittal of all appellants
- Setting aside of Trial Court and High Court orders
- Cancellation of bail bonds
- Disposal of pending applications
Legal Significance
This judgment contributes to jurisprudence by:
- Clarifying ‘public view’ requirement under SC/ST Act
- Emphasizing need for consistent evidence in caste-based cases
- Highlighting careful scrutiny needed when all witnesses are interested parties
- Balancing special legislation protections with fundamental rights of accused
The detailed evidence analysis serves as an important precedent for similar cases involving the SC/ST Act.
Petitioner Name: Hutu Ansari @ Futu Ansar & Ors..Respondent Name: The State of Jharkhand.Judgment By: Justice Sudhanshu Dhulia, Justice K. Vinod Chandran.Place Of Incident: Lohardaga, Jharkhand.Judgment Date: 06-04-2025.Result: allowed.
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