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Narad Patel v. State of Chhattisgarh

Criminal Appeal · 2019 INSC 675Decided 10 May 2019
Criminal Appeal No. 883 of 2019
Justice Arun Mishra · Justice Uday Umesh Lalit

Background

The appellant was convicted by a Special Judge in Chhattisgarh for cutting a neighbour's field embankment, which cut off the neighbour's water supply, and for abusing and threatening the complainant (a Scheduled Tribe member) and his brother at a subsequent village Panchayat meeting. He was convicted under Section 294 IPC (obscene abuse in public) and Section 3(1)(x) of the SC/ST (Prevention of Atrocities) Act, 1989, and sentenced to a few months' imprisonment with fine; he was acquitted of the criminal-intimidation charge. The High Court of Chhattisgarh affirmed both convictions in 2018, prompting this further appeal to the Supreme Court.

Decision Breakdown

The Supreme Court examined the complainant's own testimony and found that, while the complainant clearly confirmed he was abused by the appellant (justifying the Section 294 IPC conviction), the complainant's own version did not establish that the abuse referred to his caste or tribal identity: that detail appeared only in other witnesses' testimony, not the victim's own account. Giving the appellant the benefit of this doubt, the Court upheld the Section 294 IPC conviction but acquitted him of the SC/ST Act charge under Section 3(1)(x). Since the appellant had already served more than four months in custody, he was ordered to be set at liberty unless wanted in any other matter.

Lesson Learnt

A conviction under the SC/ST (Prevention of Atrocities) Act requires that the caste/tribal reference actually be established through the complainant's own testimony, not merely through corroborating witnesses: courts will give the accused benefit of the doubt where the victim's own account does not support that specific element of the offence.

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

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