The Madhya Pradesh High Court has granted leave to appeal in a case where the Trial Court acquitted an accused under the SC/ST (Prevention of Atrocities) Act despite the prosecution producing a caste certificate. The High Court found that the trial judge failed to analyze or even mention the significance of this critical evidence, rendering the acquittal legally unsustainable. This decision underscores the mandatory requirement for courts to engage with documentary proof of victimhood under the Act.
The Verdict
The State won. The Madhya Pradesh High Court granted leave to appeal against an acquittal under Section 3(1)(10) of the SC/ST Act, holding that the Trial Court committed a legal error by failing to appreciate the caste certificate issued by the SDM. The Court directed the registry to convert the petition into a criminal appeal and list it before a proper bench.
Background & Facts
The respondent, Santosh Kumar @ Lalku, was charged under Sections 294, 323 and 506-II of the Indian Penal Code and Section 3(1)(10) of the SC/ST (Prevention of Atrocities) Act, 1989. The prosecution alleged that the accused committed acts of insult and assault against a member of a Scheduled Caste. During trial, the prosecution produced a caste certificate issued by the Sub-Divisional Magistrate, establishing the victim’s Scheduled Caste status - a foundational requirement for invoking Section 3(1)(10).
The Special Judge, Anuppur, acquitted the accused of all charges under the SC/ST Act, while convicting him under Sections 294 and 323 IPC. However, the judgment contained no reasoning regarding the caste certificate. There was no discussion of its authenticity, relevance, or probative value. The order merely stated the accused was acquitted under the SC/ST Act without addressing why the documentary evidence was rejected or deemed insufficient.
The State filed a petition under Section 378(3) CrPC seeking leave to appeal against the acquittal. The petition argued that the failure to appreciate the caste certificate rendered the acquittal perverse and legally untenable.
The Legal Issue
The central question was whether an acquittal under Section 3(1)(10) of the SC/ST Act can stand when the trial court ignores or fails to appreciate the caste certificate, which is the primary evidence establishing the victim’s Scheduled Caste status and thereby the applicability of the Act.
Arguments Presented
For the Petitioner
The State contended that the caste certificate issued by the SDM is a statutory document of high probative value under the SC/ST Act. Relying on Supreme Court precedents including State of Madhya Pradesh v. Ramdas and Kunhiraman v. State of Kerala, it was argued that the absence of any analysis of this document constitutes a failure to apply the correct legal standard. The State emphasized that Section 3(1)(10) requires proof that the offence was committed because the victim belonged to a Scheduled Caste. Without appreciating the caste certificate, the trial court could not have validly concluded that this essential ingredient was absent.
For the Respondent
The respondent did not appear or file any written submissions. The Court noted the absence of any defense or counter-evidence, leaving the State’s arguments unchallenged.
The Court's Analysis
The High Court observed that the trial court’s judgment was silent on the caste certificate despite its presence in the record. This silence was not mere oversight but a legal omission. The Court held that under Section 3(1)(10), the victim’s caste status is not a mere formality - it is a substantive condition precedent to the application of the Act. The Court cited State of U.P. v. Krishna Gopal to affirm that failure to consider such a vital piece of evidence vitiates the entire finding of acquittal.
"The trial court cannot be permitted to ignore documentary evidence of caste status which is the very foundation for invoking the SC/ST Act. The absence of any reasoning on this point renders the acquittal unsustainable in law."
The Court further noted that the trial court’s acquittal under the SC/ST Act was inconsistent with its conviction under Sections 294 and 323 IPC, which were based on the same factual matrix. If the assault occurred, and the victim was a member of a Scheduled Caste as proven by the certificate, then the additional ingredient under Section 3(1)(10) was satisfied. The trial court’s failure to connect these dots amounted to a misapprehension of evidence.
The Court concluded that the case presented a substantial question of law warranting appellate review. The acquittal was not merely erroneous - it was legally infirm due to the non-application of mind to a mandatory evidentiary requirement.
What This Means For Similar Cases
This judgment reinforces that in all prosecutions under the SC/ST Act, courts must explicitly address the evidence establishing the victim’s Scheduled Caste or Scheduled Tribe status. Prosecutors must ensure that caste certificates are formally marked and properly tendered. Defence counsel cannot rely on silence to secure acquittal; the burden remains on the prosecution to prove caste status, but the court must actively evaluate that proof.
Future trial courts must now record a clear finding on the caste certificate - whether accepted, rejected, or questioned. A generic acquittal without such analysis will be vulnerable to appeal. This decision also empowers appellate courts to intervene where trial courts mechanically apply acquittal standards without engaging with statutory prerequisites.
The ruling does not alter the burden of proof but clarifies that failure to examine a key document constitutes a jurisdictional error. It does not apply to cases where caste status is not in dispute or where alternative proof (e.g., community testimony) is relied upon, but where a certificate exists and is ignored, the acquittal is liable to be set aside.
