A) ABSTRACT / HEADNOTE

Karuppudayar v. State Rep. by the Deputy Superintendent of Police, Lalgudi Trichy & Ors. examines whether the alleged caste-abuse inside a government Revenue Divisional Office amounts to an offence under Sections 3(1)(r) or 3(1)(s) of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989 by reason of the words being spoken in “any place within public view.” The FIR avers that the accused entered the complainant’s chamber, asked about the complainant’s caste, called him “Parayan” and used vulgar caste-based epithets while the complainant was performing official duties; colleagues arrived only after the incident and pacified the accused.

The Supreme Court reiterates the settled distinction between a “public place” and a “place within public view” (drawing on Swaran Singh and Hitesh Verma), holding that to be within public view the place must be so located that members of the public can witness or hear the utterance. On the FIR’s own averments the incident occurred within the four corners of the complainant’s office chamber and was not witnessed by members of the public at the time. Applying the principles in Bhajan Lal regarding quashing under Section 482 CrPC, the Court concludes that even accepting the allegations in the FIR as true they do not prima facie constitute an offence under Sections 3(1)(r) or 3(1)(s) of the SC-ST Act; the case therefore falls within the first category in Bhajan Lal and the proceedings are quashed.

Keywords: place within public view; Section 3(1)(r); Section 3(1)(s); quashing under Section 482 CrPC; four corners of the chamber.

B) CASE DETAILS

C) INTRODUCTION AND BACKGROUND OF JUDGEMENT

The present appeals arise from quashing petitions under Section 482 CrPC directed against criminal proceedings instituted after a complaint alleging caste-based abuse in a government revenue office. On 2 September 2021 the appellant, pursuing a representation for his father’s patta, is said to have been approached by the Revenue Inspector (respondent) in the Revenue Divisional Office; an altercation followed and the respondent lodged a complaint alleging that the appellant abused him using the caste name “Parayan” and resorted to vulgar caste epithets while the complainant was performing official duties.

The police registered Crime No. 676 of 2021 under Sections 294(b) and 353 IPC read with Sections 3(1)(r) and 3(1)(s) of the SC-ST Act. After investigation a charge-sheet was filed and trial commenced in the Sessions Court. The appellant sought exercise of the High Court’s inherent power under Section 482 CrPC to quash the proceedings; the Single Judge dismissed the petition and the appellant obtained special leave. The Supreme Court framed the narrow legal question whether the alleged conduct, on the FIR’s face, occurred in “any place within public view” so as to bring the offence within Sections 3(1)(r) and 3(1)(s) of the SC-ST Act, and whether the High Court erred in declining to quash the prosecution despite that material limitation. The Court also considered the correct application of the Bhajan Lal categories for quashing and the circumscribed scope of enquiry under Section 482 CrPC.

D) FACTS OF THE CASE

The factual narrative, as alleged in the FIR, is concise. On 2 September 2021 the appellant attended the Revenue Divisional Office, Lalgudi to follow up a petition seeking inclusion of his father’s name in the land patta. The Revenue Inspector (respondent) enquired, and when dissatisfied the accused allegedly asked the complainant his caste, called him “Parayan” and used vulgar caste-based language while the complainant remained inside his office chamber performing official duties.

The FIR further states that thereafter three colleagues of the complainant came to the chamber, pacified the accused and took him away indicating they arrived after the alleged abuse. Post investigation a chargesheet was filed and the Sessions Court registered Spl. S.C. No. 7 of 2022. The appellant then approached the High Court under Section 482 CrPC to quash the proceedings; the High Court refused relief. These factual averments, taken prima facie, locate the incident inside the complainant’s office chamber and do not allege the presence of members of the public who witnessed the utterances contemporaneously.

E) LEGAL ISSUES RAISED

i. Whether the alleged insults and caste-name abuse, as narrated in the FIR, occurred in “any place within public view” for the purpose of Sections 3(1)(r) and 3(1)(s) of the SC-ST Act?

ii. Whether the allegations in the FIR, taken at their face value and accepted in entirety, prima facie constitute offences under Sections 3(1)(r) or 3(1)(s) of the SC-ST Act?

iii. Whether the High Court erred in refusing to exercise the inherent jurisdiction under Section 482 CrPC to quash the proceedings in view of Bhajan Lal categories?

F) PETITIONER / APPELLANT’S ARGUMENTS

The appellant contended that even accepting the FIR allegations, the essential ingredient of “any place within public view” is absent because the abuse occurred within the four corners of his office chamber and was not open to public observation; colleagues arrived only after the incident. Learned counsel urged that the High Court failed to consider this determinative point and should have exercised Section 482 CrPC jurisdiction to quash the proceedings since the FIR did not prima facie disclose an offence under the SC-ST Act. Counsel relied on the distinction drawn in Swaran Singh and the analysis in Hitesh Verma to emphasise that a private room, not visible to the public, cannot be treated as within public view.

G) RESPONDENT’S ARGUMENTS

The State and the complainant relied upon the charge-sheet and investigative material, contending that the trial court and the High Court were justified in permitting trial. It was argued that the occurrence in an official setting may attract the SC-ST Act protections and that factual disputes as to the nature of the place and presence of others were matters for trial. The respondents submitted that the High Court properly exercised restraint under Section 482 CrPC and did not err in refusing quashing.

H) JUDGEMENT

The Supreme Court allowed the appeals and quashed the charge-sheet and all proceedings. The Court first construed Sections 3(1)(r) and 3(1)(s) of the SC-ST Act, noting that both offences require the act to occur “in any place within public view.” The Court reviewed precedent notably Swaran Singh v. State and Hitesh Verma v. State of Uttarakhand which distinguish a “public place” from a “place within public view.” Drawing those authorities, the Court held that to be a place within public view the location must be so situated that members of the public can witness or hear the abusive utterance; mere presence in a building does not suffice unless non-private members of the public were present at the time.

Applying these principles to the FIR’s averments, the Court observed that the alleged abuse occurred within the four corners of the complainant’s chamber, while colleagues arrived only after the incident hence there were no members of the public who witnessed the abuse contemporaneously. The Court emphasised that a place can be private yet within public view (for example a lawn visible from the road), but that factual feature was absent here.

Turning to the scope of Section 482 CrPC, the Court reiterated Bhajan Lal (para 102) and its categories where quashing is appropriate, including where allegations, taken at face value, do not prima facie constitute any offence. The Court found that the present case falls within that first Bhajan Lal category because even accepting the FIR as true it did not disclose the statutory element of “public view” required under Sections 3(1)(r) and 3(1)(s). The Court further noted that the High Court did not address this contention and therefore erred in declining relief.

Exercising its inherent jurisdiction sparingly but legitimately under Section 482 CrPC, the Court set aside the High Court order, quashed the charge-sheet in Spl. S.C. No. 7 of 2022 and all consequent proceedings. The result follows that prosecution under the specific SC-ST provisions could not proceed on the present FIR averments.

a. RATIO DECIDENDI

The core legal ratio is that Sections 3(1)(r) and 3(1)(s) of the SC-ST Act require the prosecution to establish that the insulting or caste-name abuse occurred in “any place within public view.” A place is within public view only when members of the public can contemporaneously witness or hear the abuse; an offence committed within the private confines of an office chamber without public presence does not satisfy this element. Where the FIR’s averments, accepted in entirety, fail to disclose that element, the case falls within the first category of Bhajan Lal and may be quashed under Section 482 CrPC. The High Court’s failure to consider this decisive legal point justified intervention by the Supreme Court.

b. OBITER DICTA 

The Court reiterated established caution on Section 482 CrPC the inherent power must be exercised sparingly and the court should not probe the veracity of allegations. Nevertheless, when on the face of the record an essential ingredient of the charged offence is missing, quashing is appropriate. The judgment endorsed the analytical distinction from Swaran Singh and Hitesh Verma between public place and place within public view, noting examples (e.g., a lawn visible from outside being within public view). The Court also emphasised that private places may sometimes be within public view depending on visibility to the public; the determination remains fact-specific and must be considered at the threshold.

c. GUIDELINES

i. When offences under Sections 3(1)(r) or 3(1)(s) of the SC-ST Act are alleged, pleadings/FIR must specifically state facts showing that the place was within public view i.e., that members of the public could witness or hear the abusive act.

ii. Courts exercising Section 482 CrPC must follow Bhajan Lal categories and may quash where, on the face of the FIR, an essential ingredient of the offence is absent.

iii. Distinguish public place from place within public view factually; visibility to passers-by or presence of non-private members at the material time determines the latter.

iv. Quashing under Section 482 should remain exceptional; however, frustration of prosecutorial excess or absence of prima facie offence warrants relief to prevent abuse of process.

v. Trial courts must scrutinise charge-sheets for existence of essential ingredients; where charge-sheets rest on allegations lacking a statutory element, appropriate preliminary objections can be raised under Section 482 CrPC or at the stage of framing charge.

I) CONCLUSION & COMMENTS

The Supreme Court’s decision reinforces that protection under the SC-ST Act is substantive but dependent on the statutory ingredients being properly pleaded and shown. The judgment strikes a balance between robust protection against caste atrocities and the necessity of preventing misuse of penal provisions by ensuring that factual allegations satisfy legal thresholds such as “place within public view.”

Practitioners should draft FIRs and complaints with precision on the contextual facts of place and presence of witnesses when invoking Sections 3(1)(r) and 3(1)(s). Conversely, accused persons have a limited but legitimate route under Section 482 CrPC where the FIR, on its face, does not make out an essential element of the offence; such quashing is warranted in the rare cases envisaged by Bhajan Lal. The judgment does not curtail substantive protections of the SC-ST Act but insists on correct legal classification and fact-finding at the threshold, thereby safeguarding both the object of the Act and the rule against prosecutorial overreach.

J) REFERENCES

a. Important Cases Referred

i. Karuppudayar v. State Rep. by the Deputy Superintendent of Police, Lalgudi Trichy & Ors., [2025] 1 S.C.R. 1381 : 2025 INSC 132.

ii. Hitesh Verma v. State of Uttarakhand and Another, [2020] 9 S.C.R. 593 : (2020) 10 S.C.C. 710.

iii. Swaran Singh and Others v. State through Standing Counsel and Another, (2008) 8 S.C.C. 435.

iv. State of Haryana and Others v. Bhajan Lal and Others, (1992) Supp. 1 S.C.C. 335.

b. Important Statutes Referred

i. Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989, ss. 3(1)(r), 3(1)(s).

ii. Code of Criminal Procedure, 1973, s. 482.

iii. Indian Penal Code, 1860, ss. 294(b), 353.