VidhiSangh

Supreme Court of India · 31/01/2025

KARUPPUDAYAR versus STATE REP. BY THE DEPUTY SUPERINTENDENT OF POLICE, LALGUDI TRICHY & ORS.

[2025] 1 S.C.R. 1381 · 2025 INSC 132

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Summary

The Supreme Court quashed a charge-sheet under Sections 3(1)(r) and 3(1)(s) of the SC-ST Act because, even on the FIR's own version, the caste abuse took place inside the complainant's office chamber with no member of the public present, so it did not occur 'in any place within public view'. The High Court had not considered this contention at all.

Issues

  1. Whether the allegations in the FIR, taken at face value, made out offences under Sections 3(1)(r) and 3(1)(s) of the SC-ST Act, in particular the element of 'any place within public view'.
  2. Whether the High Court should have exercised its power under Section 482 CrPC to quash the proceedings.

Provisions considered

Held

Result

Appeals allowed; High Court order dated 28.02.2024 set aside; charge-sheet in Spl. S.C. No. 7 of 2022 and all proceedings under it quashed.

Judgment PDF: Supreme Court of India, [2025] 1 S.C.R. 1381.