In Karuppudayar v. State 2025 the Supreme Court of India on 31.01.2025 overturned a case filed under the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989 (SC/ST Act). The Court ruled that caste-based verbal abuse within a private government office does not constitute an offence under Sections 3(1)(r) and 3(1)(s) of the Act unless it occurs in "public view." This decision prompts crucial questions about how "public view" is defined and the extent to which the SC/ST Act can be applied to cases involving caste-based verbal abuse.

Case Background:
The case originated from an incident in a Revenue Inspector's private office. The accused allegedly made derogatory caste-based remarks after learning the complainant's caste, including insults using his caste name and vulgar language. Following the abuse, colleagues intervened and removed the accused. The High Court declined to quash the case, leading to the accused's appeal to the Supreme Court.

Relevant Legal Provisions:
The case focused on Sections 3(1)(r) and 3(1)(s) of the SC/ST Act. Section 3(1)(r) criminalizes intentionally insulting or intimidating an SC/ST member with the intent to humiliate them in public view. Section 3(1)(s) penalizes caste-based abuse directed at an SC/ST individual in public view. The central legal question for the Supreme Court was whether a government official's private office qualifies as being "within public view."

Supreme Court Reasoning:
The judgment, delivered by Justices B.R. Gavai and Augustine George Masih, analysed the FIR's claims. The court recounted how the accused entered the complainant's office, questioned him, and then proceeded to abuse him with caste-based language, concluding when colleagues intervened. Significantly, the bench found that the abuse was confined to the complainant's office without public observers.

Justice Gavai, on behalf of the bench, stated that this lack of "public view" made Sections 3(1)(r) and 3(1)(s) of the SC/ST Act inapplicable. These sections criminalize caste-based insults and intimidation only when they occur in a place accessible to the public, therefore, it did not apply in this case. The arrival of colleagues after the abuse further confirmed that the act had not occurred within 'public view'.

The Court determined that an action is considered to be in "public view" only if it happens in an open area where members of the public can hear or see it. Because the alleged caste-based remarks were made within the complainant's private office and no members of the public were present, the Court concluded that the incident did not meet the Act's "public view" requirement. While colleagues arrived later, they did not witness the act itself.

Precedents Cited:
The Court cited Swaran Singh v. State (2008) and Hitesh Verma v. State of Uttarakhand (2020), which established that abuse occurring in private locations, such as an office or home, without public witnesses, does not qualify as being in "public view." These cases emphasize that for caste-based verbal abuse to be punishable under the SC/ST Act, it must occur where the public has access or where third-party witnesses are present during the incident.

Implications of the Judgment:
This ruling significantly affects how the SC/ST Act is interpreted. While the Act seeks to protect SC/ST individuals from caste-based atrocities, this decision narrows its application in cases of abuse within private spaces. The judgment might lead to a more restricted interpretation of the Act, potentially hindering victims from seeking justice when caste-based abuse occurs in controlled environments, such as government offices or private residences.

Potential Challenges and Concerns:
A key concern is that this judgment might create a loophole, allowing caste-based abuse in private settings to go unpunished. Many acts of caste discrimination occur in private, particularly in workplaces. The "public view" requirement could limit legal recourse for SC/ST members who face discrimination in such settings.

Need for Legislative Clarity:
Given the ambiguity surrounding "public view," clearer legislation is needed. The SC/ST Act could be amended to specify whether abuse in semi-private settings, like government offices, is considered to be in "public view". The legislature should also consider if the presence of any witness, even if not a member of the public, is sufficient to establish an offence under Sections 3(1)(r) and 3(1)(s).

Balancing Rights and Protection:
While this judgment protects against frivolous complaints, it also highlights the challenge of balancing stringent anti-discrimination laws with safeguards against their misuse. The ruling reinforces procedural fairness but underscores the need for a nuanced approach to caste-based abuse in official and professional situations.

Conclusion:
The Supreme Court's decision in Karuppudayar v. State sets a significant precedent concerning the scope of the SC/ST Act. By limiting its application to instances in "public view," the ruling clarifies the interpretation of Sections 3(1)(r) and 3(1)(s). However, it also raises concerns about excluding workplace and institutional caste-based abuse from legal protection. This necessitates a re-evaluation of how caste-based discrimination is addressed within legal frameworks, particularly in professional and bureaucratic areas where power dynamics often prevent effective access to justice for victims.