Hurling Caste-Based Abuses Inside Closed Room Will Not Establish SC/ST Act Case: Supreme Court

Home / Top Stories Hurling Caste-Based Abuses Inside Closed Room Will Not Establish SC/ST Act Case: Supreme Court X Supreme Court has ruled that caste-based remarks made inside a closed room, without members of the public present, do not meet the “public view” requirement under the SC/ST Act. Supreme Court quashed case against a school Manager under Sections 3(1)(r) and 3(1)(s) of the SC/ST Act. The Supreme Court has held that uttering caste-based abuses inside a room would not amount to have been uttered at a place “within public view” under the Scheduled Castes and the Scheduled Tribes (Prevention of Atrocities) Act, 1989. "The requirement of “public view” depends upon whether the alleged utterance was made in circumstances in which members of the public could witness or hear it. The mere fact that the occurrence took place within the premises of a school does not, by itself, satisfy this requirement. In the present case, the FIR and the site plan place the occurrence inside an enclosed room, while the statements of the witnesses do not establish that they were present inside the room or that they heard the alleged caste-based utterances. The material on record, therefore, does not establish that the alleged utterances were made in the presence or hearing of members of the public. The essential requirement of “public view” is consequently not satisfied," a bench of Justices Vikram Nath and Sandeep Mehta has held while quashing the case against a school Manager under Sections 3(1)(r) and 3(1)(s) of the SC/ST Act. The Manager had allegedly assaulted the parent of a students at his school. He abused and assaulted the parent with lathis, sticks and fists, along with the school staff, causing him injuries. It is further alleged that the he had used caste-based abuses. Court found that the FIR did not state that the alleged caste-based abuses were uttered in the presence or hearing of members of the public. On the contrary, the incident is alleged to have occurred inside a room in the school. The site plan dated 25th February, 2020 prepared by the Investigating Officer identifies the place of occurrence as room “A”. The material on record indicated that the room was enclosed and had no window or public access. "The prosecution case also suffers from the absence of any specific allegation of caste-based abuse against the appellant. Neither the FIR nor the statement of Respondent No. 2 attributes any specific caste-based words or slurs to the appellant. The allegation that Respondent No. 2 was abused on the basis of his caste remains general in nature. The material relied upon by the prosecution, at the highest, discloses a quarrel and scuffle between the parties. It does not disclose any specific caste-based utterance attributable to the appellant," the bench further noted. Court further found that none of these witnesses stated that they were present inside the office when the alleged caste-based abuses were uttered or that they heard any caste-based words. While they stated that they were present in the school, their statements do not establish that they witnessed or heard the alleged caste-based abuse. Their mere presence in the school premises, therefore, does not establish that the alleged utterance was made within public view, the bench has held. Case Title: RAMKRISHNA CHAUHAN VERSUS STATE OF U.P. & ANR. Bench: Justices Nath and Mehta Judgment Date: August 20, 2026