Karuppudayar vs. State represented by the Deputy Superintendent of Police, Lalgudi Trichy
Citation: 2025 INSC 132; 2025 LawText (SC) (1) 314
Bench: Justice B.R. Gavai, Justice Augustine George Masih
Background
Karuppudayar was accused under Sections 3(1)(r) and 3(1)(s) of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989 (SC-ST Act) for allegedly using a caste-based insult against a police inspector. The incident reportedly occurred inside an office chamber, not in a public place. The appellant sought quashing of the criminal proceedings, arguing that the alleged abuse did not occur “within public view,” a necessary element for offences under the cited sections of the SC-ST Act.
The Madras High Court dismissed the appellant’s petition under Section 482 CrPC, declining to quash the charge sheet and allowing the criminal trial to proceed. Karuppudayar appealed to the Supreme Court.
Supreme Court’s Analysis
Requirement of 'Public View':
The Supreme Court emphasized that for an offence under Sections 3(1)(r) and 3(1)(s) of the SC-ST Act, the alleged insult or abuse by caste name must occur “in any place within public view.” The Court relied on its prior decisions in Swaran Singh v. State (2008) and Hitesh Verma v. State of Uttarakhand (2020), which clarified that a “public place” is not synonymous with “public view”—the crucial factor is whether members of the public were present and witnessed the incident at the time it occurred.
Application to the Present Case:
The Court found that the alleged incident took place inside a private office chamber, where no members of the general public were present. The subsequent arrival of colleagues after the incident did not satisfy the “public view” requirement. The Court held that an office chamber, unless accessible to the public at the relevant time, does not constitute a place within public view.
Exercise of Inherent Powers:
Applying the principles from State of Haryana v. Bhajan Lal (1992), the Supreme Court held that even if the allegations were accepted at face value, they did not prima facie constitute an offence under the relevant sections of the SC-ST Act. The case fell within the first category of cases warranting quashing under Bhajan Lal.
Critique of High Court’s Approach:
The Supreme Court noted that the High Court had failed to consider the settled law regarding the public view requirement and thus erred in dismissing the petition for quashing.
Decision
The Supreme Court allowed the appeal, quashed the High Court’s judgment, and set aside the charge sheet and all criminal proceedings against Karuppudayar in Special S.C. No. 7 of 2022. The Court reaffirmed that the “public view” requirement is essential for prosecution under Sections 3(1)(r) and 3(1)(s) of the SC-ST Act, and that criminal proceedings cannot be sustained where this element is absent.
Significance
This judgment reinforces the necessity of the “public view” element for SC-ST Act offences, clarifies the distinction between public place and public view, and upholds the principle that criminal law must not be invoked where statutory requirements are not met. It also demonstrates the Supreme Court’s readiness to exercise its inherent powers to prevent abuse of process and protect individual rights.
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