Supreme Court Quashes SCST Act Charges Against Dr. Anand Rai, Supreme Court finds insufficient evidence to support caste-based allegations, orders trial to proceed on other charges
In a landmark judgment delivered on February 10, 2026, the Supreme Court of India has quashed charges under the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989 against Dr. Anand Rai, a prominent figure implicated in a criminal case concerning public disorder during a political event in Ratlam, Madhya Pradesh. The apex court found that the evidence presented did not sufficiently disclose the essential ingredients required to constitute caste-based offences under the Act.
The case originated from an incident on November 15, 2022, where a congregation gathered for the unveiling of a statue of Bhagwan Birsa Munda resulted in an altercation between members of the JAYS organization and security personnel, leading to injuries and disruptions. Dr. Anand Rai and several others were charged with multiple offences under the Indian Penal Code (IPC) and the SCST Act. While the trial court had framed charges under both statutes, the Supreme Court has now intervened to review the application of the SCST Act.
The Supreme Court highlighted the absence of evidence indicating caste awareness or motivation behind the alleged offences. The trial court and the High Court of Madhya Pradesh had previously upheld the charges under the SCST Act, but the Supreme Court found their analyses lacking in addressing the specific requirements of the Act. The judgment emphasized the necessity for prima facie evidence of caste-related elements, which were absent in this case.
Justice Sanjay Karol, delivering the judgment, underscored the importance of differentiating between suspicion and grave suspicion, noting that the charges could not stand without clear evidence of knowledge or intent related to the victim's caste. The court also criticized the High Court for failing to exercise its appellate jurisdiction adequately, as it did not independently scrutinize the material on record concerning the SCST charges.
The Supreme Court's decision has significant implications for the interpretation and application of the SCST Act, reaffirming the need for careful judicial scrutiny at the stage of framing charges. The court reiterated that the mere presence of charges under the IPC does not automatically warrant the application of the SCST Act, which requires specific elements to be demonstrated.
While the SCST Act charges have been dismissed, the trial against Dr. Anand Rai will proceed on other IPC charges, including unlawful assembly, causing hurt, and obstructing public servants in discharge of their duties. The Supreme Court has remitted the case back to the trial court for further proceedings in accordance with law.
This ruling serves as a reminder of the judiciary's role in safeguarding against the misuse of protective legislation while ensuring justice and accountability. The Supreme Court's decision reinforces the principle that legal provisions must be applied with precision and based on substantive evidence, preserving the integrity of both the judicial process and the rights of individuals.
Bottom Line:
Discharge under Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989 - SCST Act charges cannot stand when the material placed on record does not disclose the essential ingredients constituting caste-based offences.
Statutory provision(s): Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989 Sections 3(2)(v), 3(2)(va), 14A; Indian Penal Code, 1860 Sections 147, 341, 323, 326, 333, 427, 352, 149; Criminal Procedure Code, 1973 Sections 227, 228; Bharatiya Nagarik Suraksha Sanhita, 2023
Dr. Anand Rai v. State of Madhya Pradesh, (SC) : Law Finder Doc id # 2851438
