Recently, the Allahabad High Court revisited the contours of appellate jurisdiction under the Scheduled Castes and the Scheduled Tribes (Prevention of Atrocities) Act, 1989 (SC/ST Act, 1989). The case arose from a dispute that the parties themselves sought to resolve through compromise, prompting the Court to examine whether criminal proceedings under the SC/ST Act could be terminated within the appellate mechanism provided by Section 14-A, without invoking inherent powers under Section 482 CrPC.
The Case stemmed from criminal proceedings arising out of Case, which led to the filing of a charge sheet and a summoning order against the appellants under Section 147, Section 323, Section 500, Section 504, and Section 506 of the IPC read with Section 3(2)(va) of the SC/ST Act. The Appellants approached the High Court under Section 14-A of the SC/ST Act,1989, seeking to quash the proceedings on the basis of a compromise entered into with the complainant. Pursuant to earlier directions, the Special Judge, SC/ST Act, 1989, verified the compromise and submitted a report to the High Court. The District Magistrate also submitted that the complainant had not yet returned the compensation amount received under the statutory mechanism. With all verification records before it, the High Court proceeded to examine whether the appeal itself constituted a proper procedural route to terminate the proceedings.
The Appellants submitted that the dispute was private in nature and that the compromise had been entered into voluntarily, without coercion. It was urged that the verified settlement ought to justify quashing of the proceedings, particularly since the alleged acts were not committed on account of the complainant’s caste. Emphasising the consensual nature of the settlement, counsel insisted that continuation of prosecution would amount to an abuse of process.
On the other hand, the Respondent affirmed that the compromise was voluntary and free from undue influence. The State did not dispute the verification report but drew attention to the fact that the compensation amount had not yet been returned by the complainant, as recorded in the District Magistrate’s report.
The Court referred to the case Ramawatar v. State of M.P., noting that offences falling under the SC/ST Act, 1989, may still be quashed where the dispute is essentially private in nature, the alleged act is not motivated by the victim’s caste, or where continuation of proceedings would amount to “an abuse of the process of law.” The Bench further emphasised the Supreme Court’s caution that victims belonging to Scheduled Castes and Scheduled Tribes are “more prone to acts of coercion, and therefore ought to be accorded a higher level of protection,” requiring courts to be fully satisfied that any compromise has been entered into voluntarily and without undue influence.
The Court also relied on the Full Bench decision in Ghulam Rasool Khan and Others v. State of U.P. and Anr., observing that “a matter under the SC/ST Act may be compounded in a criminal appeal under section 14-A(1) of SC/ST Act and there is no need to take recourse of U/s. 482 Cr.P.C. for the same.” Accepting the verified compromise, the Court noted that the alleged offences were minor and not caste-motivated, making the matter fit for termination under the appellate remedy itself.
Lastly, the Court quashed the entire criminal proceedings, including the summoning order and charge sheet and allowed the criminal appeal in terms of the verified compromise. The complainant was directed to return the compensation amount to the authority concerned within one week.
Case Title: Rahul Gupta and 6 Others v. State of U.P. and Another
Case No.: Criminal Appeal No. 9930 of 2024
Coram: Hon’ble Justice Shekhar Kumar Yadav
Advocate for Appellant: Adv. Dhiraj Kumar, Romeshwari Prasad
Advocate for Respondent: G.A. Mahendra Kumar Maurya, and Adv. Vinod Kumar Bhartiya
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