DR. ANAND RAI versus STATE OF MADHYA PRADESH & ANR.

Citation: [2026] 3 S.C.R. 45 · Decided: 10-02-2026 · Supreme Court of India · Bench: SANJAY KAROL · Disposal: Appeal(s) allowed

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Judgment (excerpt)

[2026] 3 S.C.R. 45 : 2026 INSC 141
Dr. Anand Rai 
v. 
State of Madhya Pradesh & Anr.
(Criminal Appeal No. 814 of 2026)
10 February 2026
[Sanjay Karol* and Nongmeikapam Kotiswar Singh, JJ.]
Issue for Consideration
Issue arose as regards the correctness of the judgment of High 
Court wherein it dismissed the accused’s appeal against the order 
of the Special Judge whereby his prayer for discharge u/s.227 
CrPC was allowed in part arising out of proceedings wherein 
charges were framed against him under IPC and s.3(2)(v),  
3(2)(va) SC/ST Act.
Headnotes†
Code of Criminal Procedure, 1973 – s.227 – Discharge under – 
Scheduled Castes and Scheduled Tribes (Prevention of 
Atrocities) Act, 1989 – ss.3(1)(r), 3(1)(s), 3(2)(va) – Altercation 
and scuffle in a gathering – Registration of FIR – Discharge 
application filed by the accused – Trial court partly allowed 
the application – However, the High Court dismissed the 
appeal – Correctness:
Held: For a charge u/ss.3(1)(r), 3(1)(s), 3(2)(va) of the SC/ST Act to 
be established, several elements must be present – Accused must 
first commit an offence under the IPC, which are punishable with 
ten or more years of imprisonment, the act must be directed against 
a member of a Scheduled Caste or Scheduled Tribe, or against 
property that belongs to them, reflecting the special protection the 
law affords to them, and the accused must have knowledge that 
the victim belongs to a Scheduled Caste or Scheduled Tribe or that 
the property belongs to such a person – On facts, no material on 
record to establish knowledge on part of the accused – Impugned 
judgment of the High Court, does not deal at all with the charge 
under SC/ST Act, it only stated that the trial court ‘assigned elaborate 
reasons’ – Those reasons are lacking and insufficient – Only for 
* Author
46
[2026] 3 S.C.R.
Supreme Court Reports
the reason that on a facial analysis of the evidence placed on 
record, some of the charges of the IPC, appear to be met, the 
SC/ST Sections have also been charged against the accused – 
Apparent evidence on record no way sufficient for facial analysis 
of the case at hand, or enough to distinguish suspicion from grave 
suspicion – No averment whatsoever that the complainant was a 
member of the SC/ST Community – Complaint, and subsequent 
statements u/s.161 CrPC, both, appear to be lacking in averments 
for caste motivated acts allegations, one where intent is absent, 
and the other where knowledge is apparently present, seems 
difficult to accept – High Court in deciding the appeal against 
the partial order of discharge, not carried out its duty as the 
first court of appeal – Charges upon the accused in so far as 
the SC/ST Act quashed – Matter remitted back to the trial court.  
[Paras 10, 14-16, 20]
Scheduled Castes and Scheduled Tribes (Prevention of 
Atrocities) Act, 1989 – s.14A – Appeal – Powers of High Court 
as appellate court:
Held: s.14A does not curtail or dilute the ordinary appellate powers 
of the High Court – High Court does not function as a revisional or 
supervisory Court while exercising jurisdiction u/s.14-A but assumes 
the role of a first appellate court – Mechanical affirmation of the 
order of the Special Court, without independent scrutiny, would 
thus, be inconsistent with settled appellate jurisprudence and would 
amount to a failure to exercise jurisdiction – When the generally 
applicable principles are applied to an appeal u/s.14-A arising 
from a threshold order, the High Court’s role, though appellate in 
nature, stands circumscribed by the limits governing discharge – 
High Court may examine whether the allegations disclose the 
basic statutory ingredients of the offence under the Act, including 
whether the alleged act was committed on account of the victim’s 
caste and whether other foundational requirements are satisfied – 
Where these ingredients are conspicuously absent, interference 
is justified, as continuation of proceedings would amount to an 
abuse of the process of law – Even while exercising first appellate 
jurisdiction, High Court cannot, at the discharge or prima facie stage, 
adjudicate upon disputed questions of fact, assess the reliability 
of witnesses, or compare the prosecution case with the defence 
version – To do so would collapse the distinction between trial and 
[2026] 3 S.C.R. 
47
Dr. Anand Rai v. State of Madhya Pradesh & Anr.
threshold scrutiny and would result in a premature determination of 
guilt or innocence – 

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