KARUPPUDAYAR versus STATE REP. BY THE DEPUTY SUPERINTENDENT OF POLICE, LALGUDI TRICHY & ORS.

Citation: [2025] 1 S.C.R. 1381 · Decided: 31-01-2025 · Supreme Court of India · Bench: BHUSHAN RAMKRISHNA GAVAI · Disposal: Appeal(s) allowed

Cited by 2 judgment(s) · cites 2 · see the full citation network in Lexace

Judgment (excerpt)

[2025] 1 S.C.R. 1381 : 2025 INSC 132
Karuppudayar 
v. 
State Rep. by the Deputy Superintendent of Police, 
 Lalgudi Trichy & Ors.
(Criminal Appeal No(s). 496-497 of 2025)
31 January 2025
[B.R. Gavai* and Augustine George Masih, JJ.]
Issue for Consideration
Whether the incident in question occurred at a place which can be 
termed to be a place within public view; whether the allegations in 
the FIR constitute an offence either under Section 3(1)(r) or under 
Section 3(1)(s) of the Scheduled Castes and Scheduled Tribes 
(Prevention of Atrocities) Act, 1989.
Headnotes†
Scheduled Castes and Scheduled Tribes (Prevention of 
Atrocities) Act, 1989 – ss.3(1)(r) or Section 3(1)(s) – “any 
place within public view” – As per the complainant when he 
was in his office the accused came there for an enquiry from 
the complainant however, on not being satisfied, he started 
abusing him in the name of his caste and insulted him – 
Thereafter, his colleagues came there, pacified the accused 
and took him away – Allegations in the FIR, if made out a case 
that the offence was committed in public view:
Held: No – To be a place ‘within public view’, the place should be 
open where the members of the public can witness or hear the 
utterance made by the accused to the victim – If the alleged offence 
takes place within the four corners of the wall where members 
of the public are not present, then it cannot be said that it has 
taken place at a place within public view – Even as per the FIR, 
the incident took place within the four corners of the chambers of 
the complainant – His colleagues arrived at the scene after the 
occurrence of the incident – Since the incident did not take place 
at a place which can be termed to be a place within public view, 
the offence would not come under the provisions of either Section 
* Author
1382
[2025] 1 S.C.R.
Supreme Court Reports
3(1)(r) or Section 3(1)(s) of the SC-ST Act – Allegations in the FIR 
even if taken at their face value and accepted in entirety do not 
prima facie constitute an offence either u/s.3(1)(r) or under s.3(1)(s) 
of the SCST Act – Impugned judgment set aside – Chargesheet 
and all proceedings pursuant thereto quashed and set aside – Code 
of Criminal Procedure, 1973 – s.482. [Paras 11, 14, 15, 18, 21]
Code of Criminal Procedure, 1973 – s.482 – Power under, to 
be exercised sparingly with circumspection and in the rarest 
of rare cases – Discretion – Exercise of:
Held: Court will not be justified in embarking upon an enquiry as 
to the reliability or genuineness or otherwise of the allegations 
made in the FIR or the complaint – However, the court would be 
justified in exercising its discretion if the case falls under any of 
the clauses carved out by this Court in Paragraph 102 in the case 
of Bhajan Lal – Present case falls under the first category, listed 
in Paragraph 102 in the case of Bhajan Lal – Impugned judgment 
dismissing the petitions filed by the Appellant u/s.482, set aside – 
Chargesheet and all proceedings pursuant thereto quashed and 
set aside. [Paras 17, 18, 21]
Case Law Cited
Hitesh Verma v. State of Uttarakhand and Another [2020] 9 SCR 
593 : (2020) 10 SCC 710; State of Haryana and Others v. Bhajan 
Lal and Others [1992] Supp. 3 SCR 735 : (1992) Supp. 1 SCC 
335 – relied on.
Swaran Singh and Others v. State through Standing Counsel and 
Another [2008] 12 SCR 132 : (2008) 8 SCC 435 – referred to.
List of Acts
Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) 
Act, 1989; Code of Criminal Procedure, 1973.
List of Keywords
Section 3(1)(r) and Section 3(1)(s) of the Scheduled Castes and 
Scheduled Tribes (Prevention of Atrocities) Act, 1989; “any place 
within public view”; Caste name; Four corners of the wall; Members 
of the public not present; Quashing; Clauses carved out in the case 
of Bhajan Lal; Chargesheet, proceedings quashed.
[2025] 1 S.C.R. 
1383
Karuppudayar v. State Rep. by the Deputy Superintendent 
 of Police, Lalgudi Trichy & Ors.
Case Arising From
CRIMINAL APPELLATE JURISDICTION: Criminal Appeal No(s). 
496-497 of 2025
From the Judgment and Order dated 28.02.2024 of the High Court 
of Judicature at Madras at Madurai in CRLOP (MD) No. 6676 of 
2022 and CRLMP (MD) No.4621 of 2022
Appearances for Parties
Ms. Vanshaja Shukla, Ms. Ankeeta Appanna, Siddhant Yadav, 
Advs. for the Appellant.
Sabarish Subramanian, Vishnu Unnikrishnan, Siddhant Singh, 
Danish Saifi, Advs. for the Respondents.
Judgment / Order of the Supreme Court
Judg

Excerpt shown. Read the full judgment & AI analysis in Lexace.