The Telangana High Court has ruled that marital discord within a household cannot be grounds for invoking the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989. Justice E.V. Venugopal quashed criminal proceedings against a woman and her father, who were accused of caste-based insults by the woman's husband. The court emphasized that for the SC/ST Act to apply, the alleged humiliation must occur in a public place or be witnessed by independent witnesses, which was not the case in this instance.
The case originated from a complaint filed by a husband, belonging to a Scheduled Caste, who alleged that his wife and her family subjected him to caste-based humiliation following their inter-caste marriage in 2014. He claimed the abuse included derogatory remarks and threats, leading him to file a complaint under Section 504 of the Indian Penal Code and Sections 3(1)(r) and 3(1)(s) of the SC/ST (Prevention of Atrocities) Amendment Act, 2015.
However, the wife challenged the case, arguing that the allegations stemmed from marital disputes that led to a divorce decree in 2019. Her counsel cited the Supreme Court ruling in Hitesh Verma vs. State of Uttarakhand, which established that domestic disputes without public humiliation on caste grounds do not fall under the SC/ST Act. The Telangana High Court concurred, noting that the alleged insults occurred within the private confines of a home, lacking the necessary "public view" element for prosecution under the Act. The court also pointed out that the accusations lacked specific details regarding the alleged humiliation, such as time, place, and witnesses.
Justice Venugopal, invoking the inherent powers of the High Court under Section 482 of the Criminal Procedure Code (CrPC), quashed the case, stating that continuing the trial would be an abuse of the legal process. The court reiterated that while caste-based abuse is a serious offense, the law cannot be stretched to cover private disputes unless the statutory conditions are met. This ruling aligns with previous Supreme Court judgments, including Hitesh Verma vs. State of Uttarakhand and Sudhakar vs State, which clarified that private disputes without public humiliation cannot be prosecuted under the SC/ST Act. The High Court's decision underscores the importance of the "public view" requirement for offenses under the SC/ST Act, ensuring that the law is not misused to settle personal scores in matrimonial conflicts.