Rajasthan High Court Overturns Conviction in SC/ST Act Case

Judgment Finds Essential Ingredient of "Public View" Missing in Alleged Atrocities

In a pivotal judgment passed by the Rajasthan High Court on December 5, 2025, the conviction of Brij Mohan @ Raja under the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989, and the Indian Penal Code was overturned. The appellant had previously been convicted by the Special Judge in Jodhpur for offenses under Section 3(1)(x) of the SC/ST Act and Section 323 of the IPC, with sentences of six months and three months of simple imprisonment, respectively.

The case stemmed from a complaint filed by Rajan Solanki, alleging that he was insulted and physically assaulted by Brij Mohan within the premises of a private showroom, with references made to his caste. The prosecution argued that these actions constituted violations under the SC/ST Act and the IPC.

However, Justice Farjand Ali of the Rajasthan High Court meticulously analyzed the evidence and legal provisions, concluding that the essential requirement of "public view" was not met. The judgment emphasized that the alleged incident took place within the enclosed premises of a showroom, which did not satisfy the statutory criterion for public visibility required by Section 3(1)(x) of the SC/ST Act.

Furthermore, the court found no medical evidence to support the claim of physical assault, nor any corroborative proof of payment attempts made through a demand draft. The absence of these crucial elements led the court to determine that the prosecution failed to establish the offenses beyond reasonable doubt.

The judgment highlighted the misapplication of law by the trial court in convicting the appellant based on a commercial dispute rather than satisfying the stringent requirements of the SC/ST Act. Consequently, the High Court set aside the conviction and sentence, discharging the appellant from further legal obligations related to the case.

This ruling underscores the importance of adhering to statutory provisions and evidence standards in criminal trials, particularly under specialized legislation like the SC/ST Act. Legal experts anticipate that this decision will have significant implications for future cases involving similar circumstances.

Bottom Line:

Essential ingredient of "public view" under Section 3(1)(x) of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989 must be satisfied for the provision to apply. Incident occurring within private premises, such as a shop, does not fulfill this requirement.

Statutory provision(s): Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989 - Section 3(1)(x), Indian Penal Code, 1860 - Section 323.

Brij Mohan @ Raja v. State of Rajasthan, (Rajasthan) : Law Finder Doc Id # 2822863