The Supreme Court recently quashed criminal charges under the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act (SC/ST Act) against Dr Anand Rai, the whistleblower in the Vyapam scam [Dr Anand Rai vs State of Madhya Pradesh].
A Bench of Justices Sanjay Karol and N Kotiswar Singh held that no prima facie case under the SC/ST Act was made out against Anand who was booked for a 2022-incident involving alleged obstruction of public officials in Madhya Pradesh
“In that view of the matter, the charges upon the accused in so far as the SCST Act stand quashed. The matter is remitted back to the Trial Court to proceed in accordance with law regarding the other charges framed against the accused. It stands clarified that no part of the consideration made herein shall be construed as a comment on any of the charges other than the provisions of the SC/ST Act,” the Court said in its judgment passed on February 10.
The Court thus allowed a criminal appeal filed by Rai against a Madhya Pradesh High Court judgment that had refused to interfere with the trial court’s decision to frame charges against him.
The case arose from a first information report (FIR) registered at Bilpank police station in Ratlam district. According to the prosecution, a large gathering had assembled for the unveiling of a statue of Bhagwan Birsa Munda when members of the Jai Adivasi Yuva Shakti (JAYS) allegedly intercepted the vehicles of MPs, MLAs and other district officials who were arriving at the venue.
It was alleged that when security personnel attempted to clear the way, the group entered into an altercation and scuffle and pelted stones at the vehicles.
Rai was named among those said to be part of the assembly.
On March 18, 2025, the trial court went on to frame charges against him under various provisions of the Indian Penal Code(IPC) as well as Sections 3(2)(v) and 3(2)(va) of the SC/ST Act.
The Madhya Pradesh High Court later declined to quash the charges, observing that at the stage of framing of charge ,it was not necessary to attribute a specific overt act and that witness statements indicating Rai’s presence were sufficient to proceed.
Aggrieved by the High Court’s refusal, Rai approached the Supreme Court.
The Supreme Court said the material on record was “in no way sufficient” to take even a prima facie view.
“We are of the considered view that the apparent evidence on record is in no way sufficient for a facial analysis of the case at hand, or for a ‘prima facie’ view to be taken, or enough to distinguish suspicion from grave suspicion, in so far as the knowledge is concerned that would inform the accused’s alleged misdeeds,” the Court said.
It noted that the witness statements did not attribute any casteist words or abuses to the accused.
Further, the record did not indicate that Rai had knowledge that the complainant belonged to a Scheduled Caste or a Scheduled Tribe, the Court said.
“There does not appear to be any other material on record either, to establish knowledge on the part of the accused. Once the knowledge on the part of the alleged offender is in question, it is but certain that the charge cannot stand,” the Bench added.
The Court also remarked that the High Court’s judgment, though running into eighteen pages, did not deal at all with the charges under the SC/ST Act and merely recorded that the trial court had assigned elaborate reasons.
It further noted that there was “no averment whatsoever” that the complainant belonged to a SC or ST community.
The Court also underlined the human consequences of criminal trials.
“At the stage of framing of charge or considering discharge, the Court is not dealing with an abstract legal exercise. It is dealing with real people, real anxieties, and the real weight of criminal prosecution,” the judgment stated.
Senior Advocate Kapil Sibal appeared for the Rai while advocate Pashupati Nath Razdan appeared for the State.
[Read Judgment]