Case Name: DR. ANAND RAI VS. STATE OF MADHYA PRADESH & ANR.
Petition Number: Crl. Appeal arising out of SLP (Crl) No. 10711 of 2025
Citation: 2026 INSC 141
Date of Judgement: 10.02.2026
Coram: JUSTICE SANJAY KAROL & JUSTICE NONGMEIKAPAM KOTISWAR SINGH.
Background:
This case was initiated from criminal proceedings under the IPC and the SC/ST Act. Dr. Anand Rai approached the Supreme Court challenging the charges under the SC/ST Act, and not the IPC ones. The main question for determination was whether the essential ingredients required to frame charges under Sections 3(2)(v) and 3(2)(va) of the SC/ST Act were present at the stage of framing of charges.
Facts:
On 15 November 2022, a public gathering was held in Bachhadapara, Ratlam, for the unveiling of a statue of Bhagwan Birsa Munda. Allegedly, members of the JAYS organisation stopped vehicles carrying MPs, MLAs, and district officials during the event. According to the FIR, a scuffle took place between the group and police personnel. Stones were thrown at vehicles and a security personnel was injured. The road was blocked for about one hour. During the investigation, statements were recorded and a chargesheet was filed under several IPC sections as well as provisions of the SC/ST Act. During the discharge stage, the Trial Court held that there was no evidence of caste-based abuse. However, it still framed charges under Sections 3(2)(v) and 3(2)(va) of the act.
Section 3(2)(v) states that if a person commits a serious IPC (now BNS) offence which is punishable with 10 years or more against someone knowing they belong to an SC/ST community, the punishment is life imprisonment and fine.
Section 3(2)(va) states that if a person commits any offence specified in the schedule against a person or property knowing they belong to an SC/ST community, then the punishment will be the same as prescribed under the IPC (now BNS) for that offence, along with a fine. The High Court upheld this decision. Therefore, the matter reached the Supreme Court.
Issues:
- Whether the ingredients of Sections 3(2)(v) and 3(2)(va) of the SC/ST Act were even present in this case?
- Whether the High Court properly discharged its duty as a first appellate court by independently examining the material on record?
Arguments of the Parties:
The petitioner argued that the FIR or the witness statements did not mention any caste-based slur or insult. There was no specific statement that the complainant belonged to the SC/ST community. Most importantly, there was no material showing that the accused was aware about the caste of the victim. Since the knowledge of caste is an essential ingredient under Sections 3(2)(v) and 3(2)(va), the charges have no legal standing. The High Court simply agreed with the Trial Court without independently analysing whether the ingredients of the SC/ST offences were made out.
The State argued that at the stage of framing charges, the Court is not required to conduct a detailed examination of evidence. If the material creates a strong suspicion, that is sufficient to proceed to trial.
Judgement and Analysis:
The Supreme Court allowed the appeal in part. It was explained that for Sections 3(2)(v) and 3(2)(va) to apply, certain ingredients must be present. The victim must belong to an SC/ST community, and the accused must have knowledge of that fact. In this case, there was no clear statement that the complainant belonged to an SC/ST community and there was no material showing that Dr. Anand Rai knew about such caste identity. The Trial Court itself had acknowledged that there was no specific allegation of caste-based abuse. Without proof of knowledge or caste-based motive, the SC/ST Act provisions could not be sustained even at the stage of framing charges.
The Supreme Court also observed that the High Court functions as a first appellate court while hearing an appeal under Section 14-A of the SC/ST Act. The High Court must independently apply its mind to the facts and law. In this case, the High Court failed to properly examine whether the essential ingredients of the offence were present. The Supreme Court quashed the charges under Sections 3(2)(v) and 3(2)(va) of the SC/ST Act and made it clear that the IPC charges would continue.
Conclusion:
The SC/ST Act is a protective legislation meant to prevent caste-based atrocities. Its provisions cannot be applied mechanically. There must be some material to show that the offence was committed. A person should not be made to face trial if the basic legal requirements are not satisfied.
