The Supreme Court has set aside charges framed under the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989 against Dr. Anand Rai, holding that the prosecution failed to establish the essential ingredients required to invoke the special law, particularly the accused’s knowledge of the victim’s caste or any caste-based intent.
The bench of Justice Sanjay Karol and Justice Nongmeikapam Kotiswar Singh emphasized that mere allegations of participation in an incident or the existence of IPC offences cannot automatically justify adding charges under the special statute without specific material showing caste-based targeting.
The case arose from an incident on 15 November 2022 in Ratlam district, Madhya Pradesh, during a public gathering organized for the unveiling of a statue of Bhagwan Birsa Munda. According to the FIR, a group of persons allegedly intercepted vehicles of public officials, leading to a scuffle, stone-pelting, and injuries to a security personnel.
Following investigation, a chargesheet was filed alleging offences under various provisions of the Indian Penal Code, including unlawful assembly, obstruction of public servants, causing hurt, and damage to property, along with provisions of the SC/ST Act.
The trial court partly allowed an application for discharge but framed charges against Dr. Anand Rai under IPC provisions as well as Sections 3(2)(v) and 3(2)(va) of the SC/ST Act. The Madhya Pradesh High Court upheld the order, leading to the present appeal before the Supreme Court.
The principal question before the Court was whether the materials on record disclosed sufficient grounds to frame charges under the SC/ST Act, particularly whether there was evidence that the alleged offences were committed against a member of a Scheduled Caste or Scheduled Tribe; the accused had knowledge of the victim’s caste; and the act was motivated by or connected with caste identity, as required under the relevant provisions of the Act.
The Court examined the FIR, witness statements, and the trial court’s findings and noted several deficiencies. None of the statements recorded during investigation specified any caste-based abuse or slur by the accused. There was no material demonstrating that the accused knew the caste identity of the complainant or victim. The record did not even clearly aver that the complainant belonged to a Scheduled Caste or Scheduled Tribe.
The Court observed that once the requirement of knowledge or caste-based intent is not prima facie established, charges under the SC/ST Act cannot be sustained even at the stage of framing of charges.
It further held that the High Court had failed to independently examine this aspect and merely relied on the trial court’s reasoning, which itself was found insufficient.
While reiterating settled law, the Supreme Court explained that at the stage of framing of charges, courts must determine whether the material discloses all ingredients of the alleged offence. A strong suspicion may justify trial, but essential statutory ingredients cannot be presumed in the absence of supporting material.
The Court also clarified that although courts should not conduct a mini-trial at this stage, they must ensure that the allegations, taken at face value, satisfy the legal requirements of the offence invoked.
Case Details
Case Title: Dr. Anand Rai Versus State of MP
Case No.: SLP (Crl.) No. 10711of 2025
Date: 10/02/2026
