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Ramkrishna Chauhan v. State of U.P. & Anr.

Criminal Appeal · 2026 INSC 895Decided 20 Aug 2026
Criminal Appeal arising out of SLP (Crl.) No. 5113 of 2023
Justice Vikram Nath · Justice Sandeep Mehta

Background

A school manager was accused of assaulting a complainant and hurling caste-based abuse at him inside the school after a scuffle involving the complainant's son. A Special Judge summoned him under the SC/ST Act's provisions on caste-based insults committed "within public view," and the Allahabad High Court declined to quash the case.

Decision Breakdown

The Supreme Court quashed the SC/ST Act charges (while leaving ordinary IPC charges from the same FIR to proceed). It held that "within public view" requires that members of the public could actually see or hear the insult, not merely that the location was inside a building otherwise open to the public. Here, the FIR and the investigating officer's own site plan placed the incident inside an enclosed, inaccessible room, and no witness statement established that anyone actually heard the alleged caste-based words.

Lesson Learnt

A caste-based insult only attracts the SC/ST Act's stringent provisions if it happens somewhere the public could genuinely witness it, being inside a public-facing building isn't enough if the specific spot was closed off. Vague allegations without specifics won't survive scrutiny, though separate ordinary criminal charges from the same incident can still proceed.

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

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