summary of key Supreme Court judgments under the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989

 Here is a summary of key Supreme Court judgments under the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989, which have significantly shaped its interpretation and application:

---

🔹 1. Subhash Kashinath Mahajan v. State of Maharashtra (2018)

Citation: (2018) 6 SCC 454

Key Points:

• The Court issued guidelines to prevent misuse of the SC/ST Act.

• Directed that:

  • No immediate arrest should be made without prior approval of the appointing authority.

  • A preliminary inquiry must be conducted before registering an FIR.

  • Anticipatory bail can be granted if no prima facie case is made.

Impact:

• Seen as diluting the Act and led to widespread protests by Dalit groups.

• Parliament responded with an amendment to nullify this judgment (see 2018 Amendment).

---

🔹 2. Union of India v. State of Maharashtra (2019)

Citation: (2020) 4 SCC 761

Key Points:

• This decision reversed the 2018 Subhash Kashinath judgment.

• Held that the protective provisions are necessary to safeguard SC/ST rights.

• Upheld the constitutional validity of Section 18 and 18A of the Act, which bar anticipatory bail.

• Reaffirmed no need for preliminary inquiry or prior approval before FIR or arrest.

Impact:

• Restored the original intent and strength of the SC/ST Act.

---

🔹 3. Prathvi Raj Chauhan v. Union of India (2020)

Citation: (2020) 4 SCC 727

Key Points:

• Challenged the 2018 Amendment to the SC/ST Act.

• Supreme Court upheld the validity of the amendments.

• Clarified that:

  • Anticipatory bail is still barred, but courts may allow it in exceptional cases where no prima facie case is made.

• Reiterated the importance of protecting SC/ST communities from atrocities.

Impact:

• Reconciled individual rights with social justice, but kept the protective framework intact.

---

🔹 4. State of M.P. v. Ram Krishna Balothia (1995)

Citation: (1995) 3 SCC 221

Key Points:

• Challenged the bar on anticipatory bail under Section 18.

• The Court upheld the bar, stating that extraordinary protection is justified for vulnerable groups like SC/STs.

Impact:

• One of the earliest validations of the constitutionality and necessity of the SC/ST Act.

---

🔹 5. Vilubhai Khachar v. State of Gujarat (2021)

Citation: (2021) 7 SCC 527

Key Points:

• Reiterated that mere mention of SC/ST identity of the victim does not automatically attract the SC/ST Act.

• Courts must examine if ingredients of the offence under the Act are made out.

Impact:

• Emphasized judicial scrutiny to prevent false implication.

---

🔹 6. Asharfi v. State of Uttar Pradesh (2018)

Citation: (2018) 1 SCC 742

Key Points:

• Clarified that abuse or insult must be in public view to constitute an offence under Section 3(1)(r) and (s) (relating to public humiliation).

Impact:

• Narrowed scope of public insult provisions, requiring presence of third party witnesses.

---

🔹 Summary of Legal Principles:

Principle	Case
No preliminary inquiry before FIR	Union of India v. State of Maharashtra (2019)
Bar on anticipatory bail upheld	Ram Krishna Balothia (1995); Prathvi Raj (2020)
False implication protection	Vilubhai Khachar (2021)
Public view essential for insult	Asharfi v. State of U.P. (2018)
No prior approval for arrest	Union of India v. State of Maharashtra (2019)