Introduction:

In the case of Karuppudayar v. State, the Supreme Court of India, on January 31, 2025, delivered a significant judgment concerning the interpretation of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989 (SC/ST Act). The bench, comprising Justices B.R. Gavai and A.G. Masih, quashed proceedings against the appellant, Karuppudayar, who was accused of caste-based abuse against a public servant within the confines of a government office. The Court held that for an offence under Sections 3(1)(r) and 3(1)(s) of the SC/ST Act to be established, the alleged act must occur in a place “within public view,” which was not the case here.

Background:

The incident in question occurred in September 2021 inside the private chamber of a Revenue Inspector in a government office. The appellant, upon learning of the complainant’s caste, allegedly remarked, “If you people are appointed in Government service, you all will do like this only,” followed by scolding the complainant using his caste name and other vulgar words. The altercation was confined to the complainant’s chamber, with no other individuals present during the exchange. It was only after the incident that colleagues arrived and intervened. Following this, a First Information Report (FIR) was filed, leading to charges under Sections 3(1)(r) and 3(1)(s) of the SC/ST Act. The appellant’s plea to quash the proceedings was dismissed by the Madras High Court in February 2024, prompting an appeal to the Supreme Court.

Appellant’s Arguments:

The appellant contended that the alleged incident did not occur in a place “within public view,” a prerequisite for offences under Sections 3(1)(r) and 3(1)(s) of the SC/ST Act. He argued that the exchange took place within the private confines of the complainant’s chamber, with no public witnesses present. Therefore, the essential ingredient of the offence—humiliation in public view—was absent. The appellant relied on precedents, including Swaran Singh v. State (2008) and Hitesh Verma v. State of Uttarakhand (2020), where the Court had interpreted “public view” to mean that the act must be visible to the public, not merely within a private setting.

Respondent’s Arguments:

The prosecution maintained that the appellant’s actions constituted an offence under the SC/ST Act, emphasizing that the derogatory remarks were made within a government office. They argued that a government office, even if a specific chamber, should be considered a public place. The prosecution also highlighted the seriousness of caste-based abuses and the intent of the SC/ST Act to prevent such atrocities, suggesting that a strict interpretation of “public view” could undermine the Act’s purpose.

Court’s Judgment:

The Supreme Court meticulously examined the provisions of Sections 3(1)(r) and 3(1)(s) of the SC/ST Act. Section 3(1)(r) penalizes intentional insult or intimidation with intent to humiliate a member of a Scheduled Caste or Scheduled Tribe in any place within public view. Section 3(1)(s) addresses abuses directed at such members by caste name in any place within public view.

The Court observed that for an act to be considered as taking place “within public view,” it must occur in a location where the public can witness or hear the utterance. The bench stated, “To be a place ‘within public view’, the place should be open where the members of the public can witness or hear the utterance made by the accused to the victim. If the alleged offence takes place within the four corners of the wall where members of the public are not present, then it cannot be said that it has taken place at a place within public view.”

Applying this interpretation, the Court noted that the incident occurred within the private chamber of the complainant, with no other individuals present during the exchange. The colleagues arrived only after the incident had transpired. Therefore, the essential element of the offence—humiliation in public view—was missing.

The Court also referenced its earlier judgments in Swaran Singh v. State and Hitesh Verma v. State of Uttarakhand, reiterating that abuses occurring within a private setting, without public presence, do not meet the “public view” criterion necessary for offences under the specified sections of the SC/ST Act.

Consequently, the Supreme Court allowed the appeal, setting aside the Madras High Court’s decision and quashing the criminal proceedings againstthe appellant.