Supreme Court of India Judgements

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Category: SC/ST

SC/ST

Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989 (SC/ST Act) — Sections 3(1)(r) and 3(1)(s) — Essential ingredient — “in any place within public view” — Both sections require the act of insult, intimidation, or abuse to occur in a place visible to the public — This is a mandatory condition for constituting the offence.

May 12, 2026 sclaw

2026 INSC 468 SUPREME COURT OF INDIA DIVISION BENCH GUNJAN @ GIRIJA KUMARI AND OTHERS Vs. STATE (NCT OF DELHI) AND ANOTHER ( Before : Prashant Kumar Mishra and N.V.…

I P C SC/ST

CONVERSION –Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989 — Section 3(1)(r), 3(1)(s), 3(2)(va) — Penal Code, 1860 — Sections 341, 323, 506 read with Section 34 — Quashing of criminal proceedings — Appellant converted to Christianity and worked as a Pastor for ten years — High Court quashed proceedings, holding appellant disentitled to protection under SC/ST Act due to conversion — Supreme Court upheld High Court’s decision — Conversion to a religion other than Hindu, Sikh, or Buddhist results in automatic and complete loss of Scheduled Caste status — Religious conversion bars claim to benefits under SC/ST Act, as it is predicated on Scheduled Caste membership.

Mar 26, 2026 sclaw

2026 INSC 283 SUPREME COURT OF INDIA DIVISION BENCH CHINTHADA ANAND Vs. STATE OF ANDHRA PRADESH AND OTHERS ( Before : Prashant Kumar Mishra and Manmohan, JJ. ) Criminal Appeal…

SC/ST

Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989 — Section 3(1)(xi) — Conviction and Requirement of Caste-Based Intention — High Court’s finding that the offence was committed “simply for reason that the complainant was belonging to scheduled caste” held perverse — No statement in court by the victim or PW-2 suggesting that the accused were motivated by the victim’s caste — Finding based on mere observation without evidence is unsustainable. (Para 20)

Dec 9, 2025 sclaw

2025 INSC 1395 SUPREME COURT OF INDIA DIVISION BENCH DADU @ ANKUSH AND ANOTHER Vs. STATE OF MADHYA PRADESH AND ANOTHER ( Before : Dipankar Datta and Augustine George Masih,…

SC/ST

Scheduled Castes and the Scheduled Tribes (Prevention of Atrocities) Act, 1989 (SC/ST Act) — Section 3(1)(s) — Essential ingredient — Requirement of caste-based abuse occurring “in any place within public view” — Interpretation — For an offence under Section 3(1)(s) to be made out, the place where the utterance is made must be open, enabling the public to witness or hear the abuse — Abuse uttered within the four corners of a house, where public members are not present, does not satisfy the requirement of being “within public view” — Allegation that casteist abuses were hurled inside the complainant’s residence does not meet the statutory requirement — House of the complainant cannot be considered “within public view.” (Paras 9, 10, 11, 13)

Dec 9, 2025 sclaw

2025 INSC 1397 SUPREME COURT OF INDIA DIVISION BENCH SOHANVIR @ SOHANVIR DHAMA AND OTHERS Vs. STATE OF U.P. AND ANOTHER ( Before : Vikram Nath and Sandeep Mehta, JJ.…

Cr P C SC/ST

Criminal Procedure Code, 1973 — Section 482 — Quashing of proceedings — High Court quashed proceedings under SC/ST Act, 1989, against respondents — Appellant contended High Court erred in exercising jurisdiction, overlooking evidence, and conducting roving inquiry — Court held High Court’s scope under Section 482 is limited to determining if allegations disclose a cognizable offence, and it should not engage in detailed evidence evaluation at pre-trial stage — However, if allegations are baseless, motivated by personal vendetta, or lack requisite ingredients for an offence, High Court can quash proceedings to prevent abuse of process.

Jul 28, 2025 sclaw

2025 INSC 886 SUPREME COURT OF INDIA DIVISION BENCH KONDE NAGESHWAR RAO Vs. A. SRIRAMA CHANDRA MURTY AND ANOTHER ( Before : B.R. Gavai, CJI. and Augustine George Masih, J.…

SC/ST

Offence under Sections 3(1)(r) and 3(1)(s) of the SC-ST Act to be made out, the act of insult or intimidation must occur in a place “within public view,” and if the incident occurs in a private space without public witnesses, it does not satisfy the requirements of the Act. Consequently, the court can quash the proceedings if the allegations do not prima facie constitute an offence under the SC-ST Act.

Feb 4, 2025 sclaw

2025 INSC 132 SUPREME COURT OF INDIA DIVISION BENCH KARUPPUDAYAR Vs. STATE REP. BY THE DEPUTY SUPERINTENDENT OF POLICE, LALGUDI TRICHY AND OTHERS ( Before : B.R. Gavai and Augustine…

SC/ST

Offence under Sections 3(1)(r) and 3(1)(s) of the SC-ST Act to be made out, the act of insult or intimidation must occur in a place “within public view,” and if the incident occurs in a private space without public witnesses, it does not satisfy the requirements of the Act. Consequently, the court can quash the proceedings if the allegations do not prima facie constitute an offence under the SC-ST Act.

Feb 2, 2025 sclaw

2025 INSC 132 SUPREME COURT OF INDIA DIVISION BENCH KARUPPUDAYAR Vs. STATE REP. BY THE DEPUTY SUPERINTENDENT OF POLICE, LALGUDI TRICHY AND OTHERS ( Before : B.R. Gavai and Augustine…

You missed

Cr P C

Criminal Procedure Code, 1973 — Sections 209, 244 — Commitment of case exclusively triable by Court of Session — Whether Magistrate is required to record prosecution evidence under Section 244 CrPC before committing such a case, where the complaint is one instituted otherwise than on a police report — Held, no — Section 244 CrPC, which mandates the Magistrate to hear the prosecution and take evidence, occurs in Chapter XIX (Part B — “Cases instituted otherwise than on a police report”) and governs warrant-case trials before a Magistrate; it has no application where the offence (here, under Section 302 IPC) is exclusively triable by the Court of Session, which is governed instead by Section 209 CrPC — Under the scheme of the 1973 Code (unlike the erstwhile 1898 Code, which mandated a full committal inquiry with recording of evidence under Section 207-A), the Magistrate’s role at the pre-commitment stage is confined to ascertaining whether the offence is exclusively triable by the Sessions Court, and no evidence need be taken or evaluated by the Magistrate at that stage — Requiring witnesses to depose twice, once before the Magistrate and again before the Sessions Court, would serve no purpose and is not the mandate of law — High Court’s contrary view, requiring compliance with Section 244 CrPC even in a Sessions-triable case, proceeds on an erroneous reading of law and is unsustainable.

Jul 5, 2026 sclaw
Accident

Motor Vehicles Act, 1988 — Sections166, 168 — Compensation — Assessment of annual income of a self-employed deceased (wholesale grocery business) — Two ITRs filed after the death of the deceased excluded by the High Court altogether from the assessment of income — Held, following the principles in Rashmirekha Tripathy and Anr. v. The Branch Manager (Legal Claims), Sriram General Insurance Company Limited and Ors. [C.A. @ SLP(C) No.27220 of 2024, 2026 INSC 661], ITRs filed post-death call for closer scrutiny with reference to surrounding financial statements, since income may be inflated in such returns, but such returns are not to be excluded outright merely for being filed post-death — In the absence of the benefit of such surrounding financial statements on record, and it being inexpedient at this stage to remand the matter, annual income fixed with reference to the nature of the deceased’s wholesale grocery business at Rs.3,25,000 — Compensation recomputed applying 40% addition for future prospects (age 28 years), 1/4th deduction for personal expenses, and a multiplier of 17, together with conventional heads (loss of estate, funeral expenses, consortium) — Total compensation enhanced to Rs.60,79,550 (as against Rs.15,36,560 awarded by the Tribunal and Rs.38,40,850 awarded by the High Court), with interest as awarded by the Tribunal — Appeal allowed.

Jul 5, 2026 sclaw
Accident

Motor Vehicles Act, 1988 — Sections 166, 168 — Compensation — Assessment of annual income of a self-employed deceased (Insurance Agent) from Income Tax Returns — High Court had averaged the last four ITRs on record — Held, erroneous — Following the principles laid down in Rashmirekha Tripathy and Anr. v. The Branch Manager (Legal Claims), Sriram General Insurance Company Limited and Ors. [C.A. @ SLP(C) No.27220 of 2024, 2026 INSC 661], for a self-employed person the average of up to the previous three years’ ITRs, not four, is the appropriate reference point — A performance-linked spike in the income of an Insurance Agent in a particular year does not justify reaching back to an additional, earlier ITR to dilute that spike — On the facts, taking the average of the income for AY 2015-16 (Rs.4,03,180), AY 2016-17 (Rs.9,59,665) and AY 2017-18 (Rs.7,00,559), annual income assessed at Rs.6,87,802 — Compensation recomputed applying 25% addition for future prospects (age 49 years), 1/4th deduction for personal expenses, and a multiplier of 13, together with conventional heads (loss of estate, funeral expenses, consortium) — Total compensation enhanced to Rs.87,09,282 (as against Rs.49,77,000 awarded by the Tribunal and Rs.76,09,500 awarded by the High Court), with interest as awarded by the Tribunal — Appeal allowed.

Jul 5, 2026 sclaw
Accident

Motor Vehicles Act, 1988 — Sections 166, 168 — Compensation — Assessment of annual income of deceased/claimant on the basis of Income Tax Returns — Whether the ITR of the previous year alone, or the average of the previous two/three years, is to be taken — Held, no hard and fast formula governs computation of annual income; ITRs, being statutory documents, are an important reference point, but a bifurcation must be made between salaried and self-employed individuals — (i) For salaried individuals, the ITR of the previous year alone ordinarily suffices, since the financial impact of a promotion or salary revision is best reflected in that year’s return; where the deceased had not completed a year in a promoted position, or had not filed a return for that period, the Court may rely on the promotion letter and other corroborative financial statements; (ii) For self-employed persons/those running their own business, the average of the ITRs for up to the previous three years is to be taken as the reference point, having regard to the inherent income fluctuation in such professions — In assessing self-employed income, the surrounding circumstances to be additionally considered include: (a) the nature of the business (including geography and category); (b) its growth pattern and the impact of the death on the business; (c) its potential/future growth, including capital-intensive businesses profitable only at scale; (d) the possibility of negative income in initial years not reflecting the true financial standing; and (e) any other relevant factor — The date of filing of an ITR is also relevant, since income may be inflated after the death/injury; such returns call for closer scrutiny against surrounding financial statements, though they are not to be excluded outright merely for being filed post-death, if adequately supported.

Jul 5, 2026 sclaw