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Konde Nageshwar Rao v. A. Srirama Chandra Murty & Anr.

Criminal Appeal · 2025 INSC 886Decided 23 Jul 2025
Crl.A. No.-000555-000555 - 2018
Chief Justice of India B.R. Gavai · Justice Augustine George Masih

Background

The appellant, a government employee belonging to a Scheduled Caste, alleged that a Mandal Revenue Officer (Respondent No. 2) and a police Sub-Inspector (Respondent No. 1), acting at the behest of a local businessman, falsely implicated him in an unrelated criminal case in retaliation for his complaint about wrongful allotment of land meant for SC/ST beneficiaries. After he was cleared and the case against him dropped, he filed a complaint against the two respondents under the SC/ST Act alleging harassment and humiliation motivated by his caste. The Telangana High Court quashed this complaint against the respondents under Section 482 CrPC, and the appellant challenged that quashing before the Supreme Court.

Decision Breakdown

The Supreme Court held that a prosecution under the SC/ST Act requires specific evidence that the accused's actions were driven by the victim's caste status, not merely that the complainant happens to belong to a Scheduled Caste and has other ongoing disputes with the accused. Reviewing the complaint, the Court found only bald, unsubstantiated allegations without concrete instances showing caste-based intent behind the appellant's earlier false implication, and held that pending litigation between the parties alone cannot support a presumption of malicious, caste-motivated prosecution. Relying on precedent warning against misuse of the SC/ST Act to settle personal scores or harass public servants, the Court upheld the High Court's quashing order and dismissed the appeal.

Lesson Learnt

A complaint under the SC/ST Act must show specific facts establishing that the accused acted because of the complainant's caste: general grievances, personal disputes, or the complainant's caste status alone are not enough, and courts will step in early to quash prosecutions that lack this essential element.

Official source (sci.gov.in)View Judgment (PDF)

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