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Priti Agarwalla and Others vs. The State of GNCT of Delhi and Others

Not available · 2024 INSC 437Decided 17 May 2024
Not available
Justice M.M. Sundresh · Justice S.V.N. Bhatti

Background

The case arose from an equestrian training academy in Delhi, where the respondent, a trainee athlete, filed a complaint under the Scheduled Caste and Scheduled Tribe (Prevention of Atrocities) Act, 1989, against fellow trainees and their parents (the appellants), along with an application before a Magistrate seeking a police investigation. Earlier, one of the appellants had filed a complaint against the academy's administrator, and after considering all complaints, the Metropolitan Magistrate found no case was made out and dismissed the respondent's application. The Delhi High Court, however, later directed penal action against certain named public servants for allegedly failing to act on the SC/ST Act complaint, which the appellants challenged before the Supreme Court.

Decision Breakdown

The Supreme Court held that taking cognizance of an offence against a public servant under Section 4 of the SC/ST Act (for dereliction of duty) requires a proper administrative enquiry and recommendation, which had not happened here, so the High Court's direction for penal prosecution of the public servants was not in conformity with the law and was unsustainable. It further held that the Metropolitan Magistrate had correctly exercised discretion under Section 156(3) CrPC in concluding that no offence was made out on the complaints filed. The Court therefore set aside the High Court's judgment and allowed the criminal appeal.

Lesson Learnt

Public servants cannot be directed to face criminal prosecution for allegedly neglecting their duty under special laws like the SC/ST Act without first following the proper administrative enquiry procedure. Courts must adhere to this statutory safeguard even when there are serious underlying allegations.

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

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