Synopsis

The petitioners (management of a company) were accused in an FIR registered under the SC/ST Act and BNS, alleging caste-based abuses and wrongful confinement of an employee. The complainant, an employee of 18 years, was issued a show cause notice for negligence causing production loss, followed by a departmental enquiry. The complainant challenged the notice before the Industrial Tribunal; interim relief was refused. Immediately thereafter, he lodged a complaint alleging caste-based abuses. The High Court quashed the FIR, holding that: (i) the alleged incident took place within the four walls of the company premises, not a "place within public view"; (ii) the complaint was an arm-twisting tactic to avoid disciplinary action; (iii) the ingredients of offences under the SC/ST Act and Sections 351/352 BNS were not made out; (iv) special statutes cannot be mechanically invoked in civil/disciplinary disputes.

1. Heading of the judgment

High court of karnataka at bengaluru

Criminal petition no. 3478 of 2025 (with criminal petition no. 2990 of 2025)

Mr. madukar jois y.v. & ors. (petitioners) vs. State of karnataka & anr. (respondents)

Coram: hon’ble mr. justice m. nagaprasanna

Core Law: Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989 – Sections 3(1)(r), 3(1)(s), 3(2)(va) – Bharatiya Nyaya Sanhita, 2023 – Sections 351(2), 352, 127(2), 190 – Quashing of FIR – Abuse of process – Place within public view – Misuse of special statutes.

Court: High Court of Karnataka at Bengaluru
Coram: Hon’ble Mr. Justice M. Nagaprasanna (Single Judge)
Date of Judgment: June 4, 2026
Case Nos.: Criminal Petition No. 3478 of 2025 and Criminal Petition No. 2990 of 2025
Citation: 2026:KHC:26352

2. Legal framework

Major laws and provisions involved:

• Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989 – Sections 3(1)(r) (intentional insult/intimidation with intent to humiliate in public view), 3(1)(s) (abuse by caste name in public view), 3(2)(va) (enhanced punishment for offences against SC/ST)

• Bharatiya Nyaya Sanhita, 2023 – Sections 351(2) (criminal intimidation), 352 (intentional insult with intent to provoke breach of peace), 127(2) (wrongful confinement), 190 (common intention)

• Code of Criminal Procedure, 1973 / Bharatiya Nagarik Suraksha Sanhita, 2023 – Section 528 (corresponding to Section 482 CrPC – quashing of proceedings)

Subject matter of the judgment:

Whether an FIR registered under the SC/ST Act and BNS, alleging caste-based abuses and wrongful confinement in the context of a disciplinary proceeding against an employee, can be quashed when: (i) the alleged incident occurred inside the company premises, not in a public view; (ii) the complaint was filed after the employee failed to obtain interim relief in the Industrial Tribunal; and (iii) the dispute is essentially civil/disciplinary in nature.

Key legal principles applied:

... Upgrade to a Premium Plan to view the full judgment.