Keshaw Mahto @ Keshaw Kumar Mahto v. State of Bihar & Anr., 2026

The appellant was charged under IPC and SC/ST Act for allegedly abusing and intimidating a Scheduled Caste complainant at an Anganwadi centre.

The Patna High Court refused to quash the criminal proceedings initiated based on an FIR alleging caste-based abuse.

The appellant challenged the summoning order, asserting that no act of caste-based insult or intimidation was attributed to him.

Allegations were vague and did not specify the appellant’s conduct or intent to humiliate based on caste.

The case examined whether abusive language alone constitutes an offence under the SC/ST Act.

The Supreme Court set aside the criminal proceedings against the appellant.

The Court held that neither the FIR nor the charge sheet alleged any caste-based insult or intimidation attributable to the appellant.

Section 3(1)(r) requires insult or intimidation with intent to humiliate a member of a Scheduled Caste or Scheduled Tribe.

Section 3(1)(s) requires abuse “by caste name in public view” with intent to denigrate the caste.

The Court emphasized that mere insult or knowledge of caste without intent is insufficient for prosecution.

The allegations, even if accepted, did not prima facie constitute an offence under the SC/ST Act.

The appeal succeeded, the High Court’s order was set aside, and criminal prosecution against the appellant was quashed.

The Court emphasized that abusive language alone is not punishable under the SC/ST Act without intent to humiliate based on caste.

The Court highlighted that mere insult, even with knowledge of caste, is insufficient; specific intent to humiliate is necessary.

The FIR and charge sheet were vague and lacked attribution of criminal conduct to the appellant.

Section 3(1)(r) requires insult or intimidation with the intent to humiliate a Scheduled Caste or Scheduled Tribe member.

Section 3(1)(s) requires abuse “by caste name” in public view with intent denigrating the caste.

The Court observed that civil or procedural technicalities cannot substitute the substantive element of intent required under the SC/ST Act.

The judgment reinforced that criminal liability under SC/ST Act is contingent on caste-motivated intent, not general misconduct.

The Court applied precedent from Shajan Skaria v. The State of Kerala, clarifying standards for proving offences under the Act.

The decision quashed the criminal proceedings as no evidence suggested caste-based intent by the appellant.

The ruling underscores the importance of specific allegations and evidence in invoking special protection laws.