SC/ST Act Misuse: Cases, Court Rulings and Safeguards
The Scheduled Castes and the Scheduled Tribes (Prevention of Atrocities) Act, 1989, was enacted to protect historically marginalised communities from caste-based discrimination, humiliation, violence and other atrocities. It remains an important instrument of social justice and legal protection. However, cases involving deliberately fabricated complaints and the misuse of legal provisions have raised questions about accountability, investigative standards and the protection of individual rights.
Recent judicial decisions, including convictions for filing false complaints and the quashing of proceedings that failed to meet the statutory requirements, have brought renewed attention to the issue. The challenge for the justice system is to prevent misuse without weakening the protection available to genuine victims.
1. The Purpose and Legal Framework of the SC/ST Act
The SC/ST Act was introduced to address caste-based offences and provide stronger legal protection to members of Scheduled Castes and Scheduled Tribes. It establishes specific offences, provides for Special Courts and includes provisions for victim relief and rehabilitation.
Under Section 3, several acts committed by individuals who are not members of Scheduled Castes or Scheduled Tribes constitute punishable offences when the statutory conditions are satisfied. These include intentional caste-based humiliation and abuse in public view.
The law also recognises the rights of victims and witnesses under Section 15A. Its purpose is not merely to punish offenders but also to strengthen access to justice for communities that have historically faced discrimination.
Nevertheless, criminal allegations must be examined through evidence, legal requirements and established procedures. The seriousness of an allegation cannot replace the requirement to prove it.
2. Virendranath B. Tiwari Case: Bombay High Court Intervention in 2026
One significant development came from the Bombay High Court in Virendranath B. Tiwari v. State of Maharashtra, decided on 16 March 2026.
The case originated from an alleged incident at Siddharth Law College in Mumbai in June 2007. The complainant alleged that Tiwari abused her, questioned the authenticity of her certificates and assaulted her with an umbrella during an altercation. An FIR was registered in 2010, followed by a chargesheet in 2014.
Tiwari approached the High Court seeking to quash the FIR and subsequent proceedings. After examining the allegations and available material, the court found that the necessary ingredients of the relevant SC/ST Act offences had not been established. In particular, the material did not demonstrate caste-based humiliation or the use of a caste name as an insult.
The court also considered earlier proceedings involving the parties and observed that the subsequent complaint amounted to a vexatious attempt to harass Tiwari. It ultimately quashed the FIR and chargesheet.
The judgment is important because it demonstrates that courts can intervene when criminal proceedings lack the essential legal ingredients or amount to an abuse of process. However, it should not be interpreted as establishing that every unsuccessful SC/ST Act complaint is fabricated.
Source: "Bombay High Court judgment, 16 March 2026" https://indiankanoon.org/doc/98767301/
3. Parmanand Gupta Case: Conviction for Fabricated Complaints
A particularly significant case emerged from Lucknow in August 2025. A special court sentenced advocate Parmanand Gupta to life imprisonment after finding him guilty of orchestrating fabricated criminal complaints against his rivals through a Dalit woman.
According to reports, the complaints formed part of a wider attempt to target and harass an opposing family. The court convicted Gupta under provisions of the Bharatiya Nyaya Sanhita, including Sections 248 and 217, as well as Section 3(2)(5) of the SC/ST Act. It also imposed a fine of ₹5.1 lakh.
The woman involved in the proceedings was acquitted, with the court noting that she had been misled. The judgment demonstrated that deliberately manufacturing criminal allegations and exploiting protective legislation can attract serious legal consequences.
This case is particularly relevant to the debate because it involved a judicial finding of an organised attempt to misuse legal provisions, rather than an allegation based merely on an acquittal.
Sources: "The Times of India" https://timesofindia.indiatimes.com/city/lucknow/lawyer-gets-life-sentence-for-misusing-sc/st-act-to-file-fake-cases-against-rivals/articleshow/123395055.cms | "NDTV report" https://www.ndtv.com/lucknow-news/lucknow-lawyer-gets-life-sentence-for-filing-fake-cases-by-misusing-dalit-womans-identity-9122086
4. Lucknow Case: Woman Sentenced for a False Complaint
Another significant judgment was delivered by a special court in Lucknow in October 2025.
A woman was sentenced to three years and six months of imprisonment after the court found her guilty of filing a false complaint involving the SC/ST Act. The proceedings originated from a complaint registered in August 2019.
According to the reported judgment, the court convicted her under provisions concerning the furnishing of false information and making a false criminal charge with the intention of causing injury.
The court also addressed the question of financial compensation, observing that registration of an FIR alone should not be treated as sufficient proof of entitlement to compensation under the Act.
The judgment highlighted the importance of examining the evidence and establishing a prima facie case before treating allegations as substantiated.
Source: "The Times of India – Lucknow false SC/ST complaint case" https://timesofindia.indiatimes.com/india/up-woman-gets-3-5-years-jail-for-false-sc/st-act-plaint/articleshow/124968799.cms
5. Rinki Case: Conviction Following a False FIR
In another Lucknow case reported in November 2025, a special court sentenced a woman identified as Rinki to three-and-a-half years of imprisonment.
The complaint involved allegations of rape and assault under the SC/ST Act against a man with whom she had reportedly been in a relationship. The court found her guilty of filing a false FIR and convicted her under relevant provisions of the Bharatiya Nyaya Sanhita.
It imposed a fine of ₹30,000 and directed that part of the amount be paid to the person affected by the false complaint.
The judgment illustrates the legal consequences that can follow when a court establishes that criminal allegations were deliberately fabricated. It also reinforces the principle that criminal law must not become an instrument for personal retaliation.
Source: "Hindustan Times – Lucknow false FIR conviction" https://www.hindustantimes.com/cities/lucknow-news/up-woman-handed-3-5-years-jail-for-misusing-sc-st-act-101763487823071-amp.html
6. What the NCRB Data Reveals?
Individual judgments provide important examples, but national statistics offer a broader perspective.
An analysis of the National Crime Records Bureau's Crime in India 2024 data by The Dalit Project reported that police had 72,169 cases involving crimes against Scheduled Castes for investigation during 2024. Of these, 45,023 were chargesheeted, while 6,055 were closed with final reports classifying them as false.
The analysis found that cases classified as false represented approximately 11 per cent of the cases disposed of by police during that year.
Rajasthan recorded the highest number of such closures, with 3,676 cases. Haryana reported 466, while Telangana recorded 377.
These figures deserve attention, but their interpretation requires caution. A police classification of a case as false is not equivalent to a judicial conviction of the complainant for deliberately fabricating allegations. Cases closed for insufficient evidence, mistakes of fact or civil disputes are also recorded separately.
The statistics therefore indicate the scale of police-classified false cases, not the number of complainants conclusively convicted for filing malicious complaints.
Source: "NCRB 2024 data analysis – The Dalit Project" https://data.dalitproject.org/police-disposal/
7. Balancing Victim Protection and Due Process
The debate surrounding alleged misuse should not undermine the original purpose of the SC/ST Act. Genuine victims of caste-based discrimination and violence require effective legal protection, timely investigations and access to justice.
At the same time, individuals facing fabricated allegations deserve fair investigations, judicial scrutiny and appropriate remedies where deliberate wrongdoing is established.
The Supreme Court's judgment in Shajan Skaria v. State of Kerala (2024) examined the legal ingredients required to establish offences under Section 3(1)(r) of the Act. The judgment reinforced the importance of intentional humiliation and the requirement that the alleged conduct occur in a place within public view.
Such judicial scrutiny helps ensure that the Act is applied according to its statutory purpose rather than invoked without satisfying the required legal conditions.
Source: "Supreme Court judgment – Shajan Skaria v. State of Kerala" https://api.sci.gov.in/supremecourt/2023/26015/26015_2023_10_1501_54999_Judgement_23-Aug-2024.pdf
Conclusion
The misuse of the SC/ST Act, where established through credible evidence and judicial findings, is a serious concern for the administration of justice. Recent cases from Maharashtra and Uttar Pradesh demonstrate that courts can quash legally unsustainable proceedings and punish individuals found guilty of deliberately fabricating complaints.
However, a balanced approach is essential. Acquittal, insufficient evidence and a police closure report must not automatically be treated as proof of a false complaint. Equally, the protective purpose of the legislation must not become a justification for overlooking deliberate fabrication.
The credibility of the justice system depends on protecting genuine victims, safeguarding the rights of the accused and holding those who knowingly misuse the law accountable. Equal justice requires both effective protection and due process.
Sources and Further Reading
1. "Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989 – India Code" https://www.indiacode.nic.in/bitstream/123456789/1920/1/a1989-33.pdf
2. "Virendranath B. Tiwari v. State of Maharashtra – Bombay High Court, 2026" https://indiankanoon.org/doc/98767301/
3. "Parmanand Gupta Case – The Times of India, 2025" https://timesofindia.indiatimes.com/city/lucknow/lawyer-gets-life-sentence-for-misusing-sc/st-act-to-file-fake-cases-against-rivals/articleshow/123395055.cms
4. "Lucknow False Complaint Conviction – The Times of India, 2025" https://timesofindia.indiatimes.com/india/up-woman-gets-3-5-years-jail-for-false-sc/st-act-plaint/articleshow/124968799.cms
5. "Rinki Case – Hindustan Times, 2025" https://www.hindustantimes.com/cities/lucknow-news/up-woman-handed-3-5-years-jail-for-misusing-sc-st-act-101763487823071-amp.html
6. "NCRB 2024 Data Analysis – The Dalit Project" https://data.dalitproject.org/police-disposal/
7. "Shajan Skaria v. State of Kerala – Supreme Court, 2024" https://api.sci.gov.in/supremecourt/2023/26015/26015_2023_10_1501_54999_Judgement_23-Aug-2024.pdf
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