Tuesday, 20 January 2026

Supreme Court: For an offence to be made out U/S 3(1)(s) of SC/ST Act, merely abusing a member of a Scheduled Caste or a Scheduled Tribe would not be enough

Further, for an offence to be made out under

Section 3(1)(s), merely abusing a member of a

Scheduled Caste or a Scheduled Tribe would not be

enough. At the same time, saying caste name would also

not constitute an offence. {Para 15}

16. In other words, to constitute an offence under

Section 3(1)(s) it would be necessary that the accused

abuses a member of a Scheduled Caste or a Scheduled

Tribe “by the caste name” in any place within public

view. Thus, the allegations must reveal that abuses

were laced with caste name, or the caste name had been

hurled as an abuse.

Ratio: The Supreme Court held that abusive language alone is not an offence under the Scheduled Castes and the Scheduled Tribes (Prevention of Atrocities) Act, 1989, unless it is used with the intent to humiliate a person by their caste, and mere insult, even with knowledge of caste, is not punishable without such specific intent.

IN THE SUPREME COURT OF INDIA

CRIMINAL APPELLATE JURISDICTION

CRIMINAL APPEAL NO. ______ OF 2026

KESHAW MAHTO @ KESHAW KUMAR MAHTO  Vs  STATE OF BIHAR & ANR. 

Dated: JANUARY 12, 2026.

1. Leave granted.

2. This appeal arises from the order passed by the

High Court of Judicature at Patna dated 15.02.2025 in

Criminal Appeal (SJ) No. 112 of 2023, by which the

appeal preferred by the appellant herein seeking to

challenge the legality and validity of the cognizance

and summoning order dated 09.10.2020 passed by the

trial court came to be dismissed.

3. It appears from the materials on record that the

appellant herein went before the High Court praying

for the following relief:-

“quashing the order dated 09.10.2020

passed by the learned III Additional

Sessions Judge-cum-Special Judge SC/ST,

Bhagalpur passed in Shivnarayanpur,

Kahalgao, P.S.Case No. 451/2019 (G.R.No.

108/2019) offences alleged u/s 341, 323,

504, 506 and 34 of the I.P.C. and 3(i)(2)

(s) SC/ST Act pending in the Court of III

Additional District and Sessions cum

2

Special Judge, SC/ST, Bhagalpur.“

4. The case of the prosecution in brief is that on

the date of the incident, the original First Informant

was sitting alongwith his friend at the Aanganwadi

Center situated at Santhali Tola. At that point of

time, the accused persons came over there and started

abusing the First Informant. It is alleged that some

abuses relating to the caste of the First Informant

were hurled.

5. In such circumstances referred to above, the

original First Informant lodged an FIR. The FIR was

investigated and ultimately chargesheet came to be

filed against the appellant herein and other coaccused.

On 09.10.2020, IIIrd Additional District and

Sessions Judge-cum-Special Judge, SC/ST, Bhagalpur,

took cognizance of the offence under Sections 341,

323, 379, 504 and 34 of the IPC respectively and

Sections 3(i)(r)(s) of the SC/ST (Prevention of

Atrocities) Act, 1989, respectively against all the

accused persons.

6. The appellant, being dissatisfied with the

cognizance and summoning order passed by the Sessions

Court, went in appeal before the High Court under

Section 14A of the SC/ST Act. The High Court declined

to quash the prosecution insofar as the appellant is

concerned. In such circumstances, the appellant is

3

here before this Court with the present appeal.

7. We have heard Ms. Preetika Dwivedi, learned

counsel appearing for the appellant and Mr. Samir Ali

Khan, learned counsel appearing for the respondent –

State. Respondent No. 2 – original First Informant,

although served with the notice issued by this Court,

has chosen not to remain present before this Court,

either in person or through an Advocate to oppose this

appeal.

8. We enquired with the learned counsel appearing

for the State to show us some material insofar as the

present appellant is concerned, sufficient enough to

frame charge and put him into trial. The learned

counsel appearing for the State, with all fairness,

submitted that except the fact that the appellant was

also present at the relevant point of time with the

co-accused, there is no specific overt act attributed

to him.

ANALYSIS

9. We have looked into the allegations levelled in

the FIR. We tried to understand the nature of the

allegations, more particularly, so far as the present

appellant is concerned. It does not seem to be the

case of the prosecution that the appellant herein

uttered any word from his own mouth.

10. We shall fist proceed to examine whether the

necessary ingredients to constitute the offence under

Sections 3(1)(r) and 3(1)(s) of the SC/ST Act

respectively are disclosed on a plain reading of the

FIR and the chargesheet. The sections read as under:-

“3. Punishments for offences atrocities.—

[(1) Whoever, not being a member of a

Scheduled Caste or a Scheduled Tribe,—

xxx

(r) intentionally insults or intimidates

with intent to humiliate a member of a

Scheduled Caste or a Scheduled Tribe in

any place within public view;

(s) abuses any member of a Scheduled Caste

or a Scheduled Tribe by caste name in any

place within public view;”

11. This Court in Shajan Skaria v. The State of

Kerala & Anr., 2024 SCC OnLine SC 2249, laid down the

ingredients to constitute an offence under Section

3(1)(r) of the SC/ST Act. It reads thus:-

“55. The basic ingredients to constitute

the offence under Section 3(1)(r) of the

Act, 1989 are:

a. Accused person must not be a member of

the Scheduled Caste or Scheduled Tribe;

b. Accused must intentionally insult or

intimidate a member of a Scheduled Caste

or Scheduled Tribe;

c. Accused must do so with the intent to

humiliate such a person; and

d. Accused must do so at any place within

public view.”

(Emphasis supplied)

12. Section 3(1)(r) is attracted where the reason

for the intentional insult or intimidation by the

accused is that the person who is subjected to is a

member of a Scheduled Caste or a Scheduled Tribe. In

other words, the offence under Section 3(1)(r) cannot

stand merely on the fact that the

informant/complainant is a member of a Scheduled Caste

or a Scheduled Tribe, unless the insult or

intimidation is with the intention to humiliate such a

member of the community.

13. To put it briefly - first, the fact that the

complainant belonged to a Scheduled Caste or a

Scheduled Tribe would not be enough. Secondly, any

insult or intimidation towards the complainant must be

on the account of such person being a member of a

Scheduled Caste or a Scheduled Tribe.

14. With a view to dispel any doubt and lend clarity,

we deem it appropriate to mention that even mere

knowledge of the fact that the complainant is a member

of a Scheduled Caste or a Scheduled Tribe is not

sufficient to attract Section 3(1)(r).

15. Further, for an offence to be made out under

Section 3(1)(s), merely abusing a member of a

Scheduled Caste or a Scheduled Tribe would not be

enough. At the same time, saying caste name would also

not constitute an offence.


16. In other words, to constitute an offence under

Section 3(1)(s) it would be necessary that the accused

abuses a member of a Scheduled Caste or a Scheduled

Tribe “by the caste name” in any place within public

view. Thus, the allegations must reveal that abuses

were laced with caste name, or the caste name had been

hurled as an abuse.

17. What appears from the aforesaid is the element of

humiliation is present in Section 3(1)(s) as well. It

has to be gathered from the intentional insult towards

the caste, and the content. The content under Section

3(1)(s) are the abuses hurled at a person belonging to

a Scheduled Caste or a Scheduled Tribe. However, the

intent with which the abuses were hurled must be found

to be denigrating towards the caste, resulting into a

feeling of caste-based humiliation.

18. In the case at hand, we find that there is

nothing on record to indicate that the alleged acts of

the appellant were motivated for the reason that the

complainant is a member of a Scheduled Caste or a

Scheduled Tribe. Neither the FIR nor the chargesheet

contains any whisper of an allegation of insult or

intimidation by the appellant herein, let alone one

made with the intention to humiliate the complainant.

19. The allegations levelled in the FIR, even if

taken at their face value and accepted in their

entirety, do not prima facie, constitute an offence

under either Section 3(1)(r) or under Section 3(1)(s)

of the SC/ST Act.

20. Insofar as the offences under the IPC, the

allegations do not inspire confidence. We find that

the allegations levelled against the appellant in the

FIR do not meet the essential ingredients of any of

the offences and are rather general in nature. Mere

presence of the appellant does not establish his

participation in the alleged offence.

21. In such circumstances referred to above, we are

of the view that putting the appellant into trial,

along with other co-accused, will be travesty of

justice.

22. In view of the above, this appeal succeeds and is

hereby allowed. The impugned order passed by the High

Court is set aside and the criminal prosecution

against the appellant herein is hereby quashed.

23. Pending interlocutory application(s), if any,

is/are disposed of.

……………………………………………………………………….J.

[J.B. PARDIWALA]

…………………………………………………………………...J.

[ALOK ARADHE]

NEW DELHI;

JANUARY 12, 2026.


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