Supreme Court Quashes SC/ST Act Proceedings for Lack of "Public View" and Specific Caste-Based Allegations

Case Snapshot

• Case Name: Ramkrishna Chauhan v. State of U.P. & Anr.

• Citation: 2026 INSC 895

• Bench: Justice Vikram Nath

• Date of Judgment: August 20, 2026

• Area of Law: Criminal Law, Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989

The Judgment in One Line

SC/ST Act proceedings quashed as caste-based abuses were allegedly uttered inside an enclosed room, not "within public view."

Why This Judgment Matters

This judgment is significant as it clarifies the crucial requirement of "any place within public view" under Sections 3(1)(r) and 3(1)(s) of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989. The Supreme Court has held that mere presence in a school premises does not satisfy the "public view" requirement—the utterance must be made in circumstances where members of the public could witness or hear it. The judgment also emphasizes that general and vague allegations of caste-based abuse, without specific words attributed, are insufficient to sustain proceedings. This will guide trial courts in scrutinizing SC/ST Act complaints more carefully at the cognizance stage.

Background

Respondent No. 2 lodged an FIR on January 25, 2020, against the appellant and other co-accused for offences under Sections 147, 323, 342, and 504 IPC and Sections 3(1)(r) and 3(1)(s) of the SC/ST Act. The

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