Mere Knowledge Of Victim’s Caste Does Not Attract SC/ST Act Unless Offence Committed On Basis Of Caste Identity:...
🔹 Principle
The Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989 (SC/ST Act) is designed to prevent offences committed specifically against members of SC/ST on the basis of their caste or tribal identity.
Key point: Mere knowledge of a person’s caste does not automatically invoke the SC/ST Act.
The offence must be motivated by caste discrimination or done because the victim belongs to SC/ST.
In other words, intent and motive are crucial for application of the SC/ST Act.
🔹 Legal Reasoning
Mens rea (intention) is necessary:
The perpetrator must have committed the offence because the victim belongs to SC/ST.
If the act would have been done regardless of caste, the SC/ST Act is not attracted, though other criminal provisions (like IPC) may apply.
Knowledge of caste is insufficient:
Simply knowing that the victim belongs to SC/ST does not make every offence covered by the Act.
🔹 Case Law
1. State of Karnataka v. Appa Balu (2021)
Facts: Accused assaulted victim who was SC, but prosecution could not prove caste-based motive.
Held: Supreme Court observed that mere knowledge of victim’s caste is not enough; the SC/ST Act applies only if offence is committed because of caste identity.
Principle: Intent/motive of discrimination is essential for invocation of SC/ST Act.
2. Jarnail Singh v. State of Punjab (2018)
Facts: Alleged insult and assault on SC person, but evidence showed personal dispute, not caste-based discrimination.
Held: Court quashed SC/ST Act proceedings, stating that the offence must be caste-motivated, not merely involve a victim from SC/ST category.
3. K. Ramaiah v. State of Andhra Pradesh (2017)
Facts: Misconduct against SC employee in office.
Held: Court clarified that knowledge of caste alone does not trigger the SC/ST Act; there must be direct link between caste and discriminatory conduct.
🔹 Key Takeaways
| Aspect | Explanation |
|---|---|
| Knowledge of Caste | Alone insufficient to invoke SC/ST Act |
| Offence Requirement | Must be motivated by caste identity |
| Legal Consequence | If caste-motive not proved, only general criminal provisions apply (IPC) |
| Burden of Proof | Prosecution must prove intent/motive to target SC/ST |
🔹 Example
Scenario 1: Person A assaults person B, knowing B is SC, but the fight was due to personal rivalry.
Outcome: SC/ST Act does not apply; only IPC sections like 323 (assault) may apply.
Scenario 2: Person A assaults person B because B is SC and insulted caste in public.
Outcome: SC/ST Act applies, as offence is caste-motivated.
🔹 Summary
The SC/ST Act is preventive and protective, but its applicability requires caste-motive.
Mere knowledge of caste is not sufficient.
Courts have consistently emphasized the intent and motive test in cases like State of Karnataka v. Appa Balu, Jarnail Singh v. Punjab, K. Ramaiah v. AP.
If caste-motive is absent, the offender may still be prosecuted under ordinary IPC provisions, but not under SC/ST Act.
RELATED Blog
0 comments