Telangana High Court quashes SC/ST Act case citing lack of ‘intention to humiliate’

A bench of Justice Juvvadi Sridevi observed that the dispute was fundamentally related to the event arrangements and monetary issues, making it “at best a private dispute” that “cannot be allowed to be converted into criminal proceedings under the special statute”. The court found that the complaint “lacks any foundational allegation that the petitioner-accused intentionally targeted or humiliated the complainant on the sole ground of caste”.

The court found “significant inconsistencies” in the utterances allegedly made by Agarwal as attributed by Gaikwad and the other witnesses. The court found these inconsistencies to “raise grave doubt regarding their authenticity” and “strongly suggest improvements might have been introduced at a later stage”. The court added that “the alleged words are not consistent either in content or in sequence, raising grave doubt regarding their authenticity.”
Supreme Court ruling in 2023

The high court emphasised that the “continuation of the criminal proceedings against the petitioner-accused would amount to an abuse of the process of law, and the same is liable to be quashed”. The court relied on the Supreme Court’s 2023 ruling in the B Venkateswaran and others versus P Bakthavatchalam case and held that “a purely civil dispute cannot be permitted to be converted into criminal proceedings under the Act merely by alleging caste-based abuses, particularly when the essential ingredients of the offence are not disclosed”.

Regarding the charge under section 506 of the Indian Penal Code (criminal intimidation), the court held that the alleged threats were “vague expressions made in the heat of altercation and do not satisfy the statutory requirements of criminal intimidation”. The court also noted that the trial court erroneously included IPC section 420, even though no element of cheating was present.

The judge also pointed to the “unexplained delay of three days in filing the police complaint and nearly one month in filing the private complaint”, stating that the failure to provide a plausible reason “materially creates doubt over the credibility of the prosecution version”.