Supreme Court Acquits Accused in SC/ST Act Case, Citing Lack of Credible Evidence

Supreme Court Overturns Conviction in Madhya Pradesh Case, Highlights Inconsistencies in Prosecution's Evidence

In a significant ruling, the Supreme Court of India has overturned the conviction of Dadu @ Ankush and Ankit, who were previously found guilty under Sections 354 and 323 of the Indian Penal Code and Section 3(1)(xi) of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989. The judgment, delivered on December 8, 2025, by Justices Dipankar Datta and Augustine George Masih, highlighted several discrepancies and inconsistencies in the prosecution's evidence, ultimately leading to the acquittal of the accused.

The case originated from an incident on October 4, 2015, in Sawargaon, Madhya Pradesh, where the victim alleged that the accused had assaulted her and her brother, while also making caste-based derogatory remarks. The Special Court had sentenced Ankit to one year of rigorous imprisonment and Dadu to three months, based on the victim's testimony and the evidence presented.

However, upon appeal, the Supreme Court found notable contradictions between the victim's initial complaint and her courtroom testimony, particularly regarding the presence and actions of the accused. The Court observed that the injuries reported were minor and could have been caused by a fall, as suggested by the medical officer, rather than an assault. Furthermore, the absence of corroborative witnesses, despite claims of public presence during the incident, weakened the prosecution's case.

The Court also criticized the High Court's reliance on abrupt findings regarding the caste-based motive, which were unsupported by trial statements. It emphasized the importance of scrutinizing the testimony of hostile witnesses, noting that the High Court had erred in dismissing such evidence without proper consideration.

In its judgment, the Supreme Court concluded that the evidence did not prove the accused's guilt beyond a reasonable doubt, leading to the setting aside of the conviction and sentence. The accused have been released, and the appeal allowed, marking a pivotal moment in the interpretation of evidence in cases involving the SC/ST Act.

Bottom Line:

Conviction under Sections 354, 323 IPC and Section 3(1)(xi) SC/ST Act set aside due to discrepancies in prosecution evidence, lack of corroboration, and absence of credible testimony.

Statutory provision(s): Indian Penal Code, 1860 Sections 323, 354; Scheduled Castes and The Scheduled Tribes (Prevention of Atrocities) Act, 1989 Section 3(1)(xi); Criminal Procedure Code, 1973 Section 313; Evidence Act, 1872.

Dadu @ Ankush v. State of Madhya Pradesh, (SC) : Law Finder Doc Id # 2819230