Supreme Court Clarifies: Insult Under SC/ST Act Must Be Linked to Victim’s Caste Identity
Abusive language alone not punishable unless caste-based humiliation proven
Court sets aside proceedings, stresses intent and context in applying SC/ST Act
By Our Legal Reporter
In a landmark ruling, the Supreme Court of India has clarified the scope of offences under the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989. The Court held that mere use of abusive language or insults does not constitute an offence under the Act unless the insult is specifically on account of the victim’s caste identity.
The judgment, delivered by a bench of Justices J.B. Pardiwala and Alok Aradhe, set aside criminal proceedings against an accused where neither the FIR nor the charge-sheet alleged caste-based humiliation. The Court emphasized that the legislative intent of the Act is to protect SC/ST communities from targeted caste-based atrocities, not to criminalize general abusive language.
Background of the Case
- The case involved allegations of abusive language against a person belonging to an SC community.
- The FIR and charge-sheet did not mention any caste-based insult or humiliation.
- Both the trial court and the High Court proceeded under the SC/ST Act despite the absence of caste-specific allegations.
- The Supreme Court quashed the proceedings, ruling that intent to humiliate based on caste is essential for an offence under the Act.
Key Observations by the Supreme Court
- Intent matters: Abusive language alone is not punishable unless used with the intent to humiliate a person because of their caste.
- Knowledge of caste insufficient: Even if the accused knows the victim’s caste, that alone does not make the insult an offence.
- Legislative purpose: The Act aims to protect SC/ST communities from targeted caste-based atrocities, not general quarrels or insults.
- Error by lower courts: Both the trial court and High Court erred in proceeding under the Act without caste-specific allegations.
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Comparison Table
|
Aspect |
General Abuse |
Caste-Based Abuse |
|
Punishable under SC/ST Act? |
❌ No |
✅ Yes |
|
Requires intent to humiliate? |
❌ Not applicable |
✅ Essential |
|
Knowledge of caste enough? |
❌ No |
❌ No, intent must be proven |
|
Court’s stance |
Not covered by Act |
Covered if humiliation is caste-linked |
Why This Ruling Matters
- For victims: Ensures genuine caste-based atrocities are punished while preventing misuse of the law.
- For accused persons: Protects individuals from false or exaggerated charges where caste is not the basis of insult.
- For courts: Provides clarity on interpreting SC/ST Act provisions, ensuring consistency in rulings.
- For society: Reinforces the principle that the Act is a shield against caste oppression, not a tool for settling personal disputes.
Broader Legal Context
This ruling builds on earlier precedents:
- In Hitesh Verma v. State of Uttarakhand (2020), the Supreme Court held that insults not linked to caste identity do not attract the SC/ST Act.
- In Karuppudayar v. State (2025), the Court clarified that caste-based insults must occur in public view to constitute an offence.
- The latest judgment reaffirms that specific intent and context are crucial in applying the Act.
Risks & Limitations
- Risk of misuse: Without clear allegations, false cases may be filed under the Act.
- Judicial caution: Courts must carefully examine FIRs and charge-sheets to ensure caste-based intent is alleged.
- Trade-off: While protecting accused persons from misuse, victims may face challenges proving intent in genuine cases.
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Conclusion
The Supreme Court’s ruling is a landmark in interpreting the SC/ST (Prevention of Atrocities) Act. By holding that insults must be directly linked to caste identity to constitute an offence, the Court has reinforced the principle of fairness and intent in criminal law.
This judgment ensures that the Act remains a powerful tool against caste-based atrocities while preventing its misuse in ordinary disputes. It provides clarity for victims, accused persons, and courts, strengthening the balance between justice and protection of rights.
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