Case Note & Summary
The Supreme Court examined an appeal challenging the High Court's dismissal of the appellant's discharge application -- The case originated from FIR No. 0653 of 2022 involving allegations of unlawful assembly, obstruction, assault, and caste-based offences during a public event -- The Trial Court had partly allowed discharge, but the High Court upheld most charges -- The Supreme Court analyzed the legality of investigation conducted by an Inspector under SC/ST Act, finding it valid per State notification -- However, the Court held that the material on record failed to establish prima facie case for offences under SC/ST Act or specific IPC charges against the appellant -- Emphasizing the limited scope at charge framing stage, the Court quashed all charges and discharged the appellant
Headnote
The Supreme Court allowed the appeal and set aside the impugned judgment of the High Court -- The Court held that the investigation was not vitiated as the State Government notification authorized Inspectors to investigate specified offences under SC/ST Act -- At the charge framing stage, the Court's role is limited to examining whether prima facie evidence exists to proceed with trial, not to conduct a mini-trial -- The material on record did not disclose sufficient ground to presume commission of offences under SC/ST Act -- Charges under IPC sections were also found unsustainable due to lack of specific allegations against the appellant -- The appellant was discharged from all charges under Section 227 of Code of Criminal Procedure, 1973
Premium Content
The Headnote is only available to subscribed members.
Subscribe Now
to access key legal points
Issue of Consideration: The Issue of whether the charges framed against the appellant under various sections of IPC and SC/ST Act were legally sustainable based on prima facie evidence and procedural compliance
Premium Content
The Issue of Consideration is only available to subscribed members.
Subscribe Now
to access critical case issues
Final Decision
The Supreme Court allowed the appeal, set aside the High Court's judgment, and discharged the appellant from all charges under Section 227 CrPC
2026 LawText (SC) (02) 27
Criminal Appeal No. ______ of 2026 (Arising out of SLP (Crl.) No. 10711 of 2025)
SANJAY KAROL J. , NONGMEIKAPAM KOTISWAR SINGH J.
Mr. Kapil Sibal, learned Senior Counsel for the accused and Mr. Pashupati Nath Razdan, learned Advocateon-Record for the State
State of Madhya Pradesh & Anr.
Premium Content
The Indexes are only available to subscribed members.
Subscribe Now
to access critical case indexes
Nature of Litigation: Criminal appeal against dismissal of discharge application in SC/ST Act case
Remedy Sought
Appellant sought discharge from charges under IPC and SC/ST Act
Filing Reason
Challenging High Court's affirmation of charges framed by Trial Court
Previous Decisions
Trial Court partly allowed discharge application -- High Court dismissed appeal against Trial Court's order -- Supreme Court granted bail earlier
Issues
Whether investigation by Inspector instead of DSP vitiated proceedings under SC/ST Act
Whether prima facie evidence existed to frame charges under IPC and SC/ST Act
Whether discharge should be granted under Section 227 CrPC
Submissions/Arguments
Appellant challenged investigation legality under SC/ST Act rules
Prosecution argued sufficient material existed for charge framing
Appellant contended lack of specific allegations and prima facie evidence
Ratio Decidendi
At charge framing stage, court must only examine if prima facie evidence exists -- Investigation by Inspector was valid per State notification under Section 9 SCST Act -- Material on record did not disclose sufficient ground for presumption of guilt under SC/ST Act or specific IPC offences
Judgment Excerpts
The Court held that the State Government is expressly empowered to confer powers of investigation on officers below the rank of DSP for specified categories of offences
The exercise is limited to examining whether the material placed by the prosecution, if taken at face value, discloses sufficient ground to presume that the accused has committed the alleged offences
The degree of satisfaction required is only that of a strong suspicion and not proof beyond reasonable doubt
Procedural History
FIR registered on 15 November 2022 -- Chargesheet filed on 16 February 2023 -- Trial Court partly allowed discharge application -- High Court dismissed appeal on 3 July 2025 -- Supreme Court granted leave and heard appeal
Premium Content
The Indexes are only available to subscribed members.
Subscribe Now
to access critical case indexes
