High Court Must Independently Apply Its Mind On SC/ST Act Charges In Appeal Under Section 14A : Supreme Court

The Supreme Court has criticized the Madhya Pradesh High Court's handling of a case under the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities Act)( SC/ST Act), noting that despite the absence of the basic ingredients of the offence being met, i.e., intentional caste-based insult or intimidation, the High Court proceeded with the criminal proceedings.The Supreme Court held that while exercising appellate jurisdiction under Section 14A of the SC/ST Act, a High Court does not sit as a revisional or supervisory court but functions as a first appellate court. A mechanical affirmation of a Special Court's order, without independent scrutiny of the material on record, would amount to a failure to exercise jurisdiction, the Court said.A Bench of Justices Sanjay Karol and N. Kotiswar Singh was hearing an appeal that arose from a November 15, 2022 incident during the unveiling of a statue of Bhagwan Birsa Munda at Bachhadapara in Madhya Pradesh. According to the prosecution, a large group allegedly associated with the JAYS organisation intercepted officials, pelted stones at vehicles, and assaulted personnel, resulting in injuries to a security official. Appellant-Dr. Rai was named as one of the accused.The Trial Court had partly allowed the Appellant's discharge application. While it dropped certain charges, it retained charges under Sections 147, 341, 427, 353, 332, 333, 326, 352 and 323 read with Section 149 of the IPC, along with Sections 3(2)(v) and 3(2)(va) of the SC/ST Act. The Madhya Pradesh High Court dismissed his statutory appeal under Section 14-A of the SC/ST Act, prompting the appellant to approach the Supreme Court. Before the Supreme Court, the sole issue was the sustainability of the charges under the SC/ST Act.High Court's Role Under Section 14AThe Court underscored that an appeal under Section 14A of the SC/ST Act is a statutory first appeal, both on facts and law. Even if the appellate court ultimately agrees with the Special Court, its judgment must reflect that it independently examined the material and applied its mind."The High Court does not function as a revisional or supervisory Court while exercising jurisdiction under Section 14-A but assumes the role of a first appellate court. A mechanical affirmation of the order of the Special Court, without independent scrutiny, would therefore be inconsistent with settled appellate jurisprudence and would amount to a failure to exercise jurisdiction. Even where the appellate Court ultimately agrees with the reasoning of the Courts below, the judgment must disclose that the material was independently examined."At the same time, the Bench clarified that the width of appellate power depends on the stage of proceedings. While appeals against conviction or acquittal permit comprehensive reappreciation of evidence, a different discipline applies at the stage of discharge or framing of charge.Relying on settled precedents including State of Bihar v. Ramesh Singh and Union of India v. Prafulla Kumar Samal, the Court reiterated that at the threshold stage, the test is whether the material, taken at face value, discloses the essential ingredients of the alleged offence and raises grave suspicion. Courts are cautioned against conducting a roving inquiry or weighing evidence as if at trial.Thus, while hearing an appeal against an order framing charges under the SC/ST Act, the High Court must examine whether the basic statutory ingredients are prima facie made out. If those foundational elements are absent, interference is justified. However, the appellate court cannot adjudicate disputed facts or evaluate witness credibility at this stage."Thus, the appellate power under Section 14-A of the SC/ST Act must be exercised in harmony with the broader framework of criminal procedure. While the High Court is duty- bound, as a first appellate Court, to independently apply its mind and correct errors committed by the Special Court, it must remain conscious of the stage of the proceedings and the corresponding limits of judicial scrutiny. This calibrated approach ensures that the protective object of the SC/ST Act is preserved, while simultaneously safeguarding against mechanical application of its provisions in cases where the statutory ingredients are not even prima facie disclosed."Quashing charges framed under the SC/ST Act, the Court said that when an statutory appeal is filed against the framing of charges, it is not incumbent upon the High Court to do a roving enquiry into the allegations, rather their role is limited to ascertaining whether the allegations disclose the basic statutory ingredients of the offence under the Act, i.e., whether the alleged act was committed on account of the victim's caste and whether other foundational requirements are satisfied. “…the test is whether the material on record, taken at face value, discloses the essential ingredients of the alleged offence and gives rise to a strong or grave suspicion against the...

High Court Must Independently Apply Its Mind On SC/ST Act Charges In Appeal Under Section 14A : Supreme Court

Yash Mittal

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