In a significant ruling, the Telangana High Court has thrown out criminal proceedings initiated under the stringent Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act against a Hyderabad-based businessman. The court concluded that the case stemmed from a private financial disagreement over a cancelled New Year's party and lacked the essential element of an intention to humiliate the complainant based on his caste.
The Core of the Dispute: A Failed New Year Event
The legal battle originated from a soured business arrangement between businessman Vijay Kumar Agarwal and complainant Akshay Gaikwad. According to the complaint, Gaikwad was tasked with organising a New Year event at Agarwal's godown scheduled for December 31, 2021. The plan fell apart after the police denied permission for the gathering.
Gaikwad alleged that Agarwal, who had reportedly invested Rs 9.8 lakh in the event, became enraged. He claimed that in the presence of over 25 people, Agarwal used abusive language and caste-based slurs against him, including a derogatory reference to 'SC Mahar ke bache'. This led to the filing of an FIR under the SC/ST Act and sections of the Indian Penal Code.
Court Finds Inconsistencies, Absence of Caste Intent
A bench led by Justice Juvvadi Sridevi meticulously examined the case and found several flaws in the prosecution's narrative. The judge pointed out "significant inconsistencies" in the alleged utterances attributed to Agarwal by Gaikwad and other witnesses. The court noted that these inconsistencies in content and sequence "raise grave doubt regarding their authenticity" and suggested possible improvements to the story at a later stage.
Most crucially, the bench observed that the complaint "lacks any foundational allegation" that Agarwal intentionally targeted Gaikwad solely because of his caste. The judge ruled that the dispute was fundamentally about event arrangements and monetary loss, making it "at best a private dispute." The court emphasised that such a civil disagreement cannot be transformed into a criminal case under the special SC/ST statute merely by adding allegations of caste abuse.
Reliance on Supreme Court Precedent and Other Charges
The High Court's decision heavily relied on a landmark 2023 ruling by the Supreme Court in the case of B Venkateswaran and others versus P Bakthavatchalam. The apex court had held that "a purely civil dispute cannot be permitted to be converted into criminal proceedings under the Act merely by alleging caste-based abuses," especially when the core ingredients of the offence are missing.
Applying this principle, the Telangana HC stated that continuing the prosecution would be "an abuse of the process of law." The court also dismissed the accompanying charge under IPC Section 506 (criminal intimidation), stating the alleged threats were vague expressions made in the heat of an argument and did not meet the legal threshold.
Furthermore, the bench noted that the trial court had erroneously added IPC Section 420 (cheating), even though no element of cheating was involved. The judge also highlighted an unexplained delay of three days in filing the police complaint and nearly a month in filing a private complaint, which cast doubt on the prosecution's version of events.
This ruling underscores the judiciary's stance on preventing the misuse of powerful legislation meant to protect marginalised communities, ensuring it is applied in cases of genuine caste-based atrocity and not weaponised in personal or financial conflicts.
