Court holds no caste-based insult or premeditation in filming vaccination program; continuation of criminal case deemed abuse of process of law
In a significant judgment delivered on September 21, 2026, the Karnataka High Court quashed criminal proceedings initiated under the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989 against Sri Manjunath, a cameraman who was covering a Covid-19 vaccination program. The petitioner had faced allegations of caste-based abuse and physical assault during an altercation at the vaccination site in Malleshwaram, Bengaluru.
The complaint alleged that the petitioner, while filming the vaccination drive at a government school, abused a complainant by invoking caste names to degrade her publicly and also physically assaulted her. Based on this complaint, the police registered a case under Sections 3(1)(r) and 3(1)(s) of the SC/ST Act, alongside Sections 341, 323, and 506 read with Section 34 of the Indian Penal Code.
Sri Manjunath challenged the proceedings through a writ petition under Article 226 of the Constitution and Section 482 of the Criminal Procedure Code, asserting that he was a stranger to the complainant and had no intention to insult or harm anyone on caste grounds. He argued that his presence at the vaccination site was purely professional to cover the event for news purposes, and any filming of the complainant or others was incidental without any obscene intent.
After hearing the submissions of both parties, Justice V Srishananda observed that the petitioner's role was limited to capturing the vaccination program as a media person, with no premeditated intention to insult or assault. The court held that merely filming individuals present at the event does not amount to an offence under the SC/ST Act or the IPC unless there is clear evidence of intention to commit caste-based insult or assault.
The court further noted that the complaint alone, without supporting material or evidence, was insufficient to sustain the prosecution. It emphasized that continuing the criminal proceedings in the absence of substantive material would amount to an abuse of the process of law.
Consequently, the Karnataka High Court allowed the petition and quashed the entire proceedings pending in Special Case No. 773/2022 before the LXX Additional City Civil and Sessions Judge, Bengaluru. This judgment reinforces the principle that invocation of stringent provisions like the SC/ST Act requires clear evidence of intent and cannot be based solely on complaint averments.
Bottom Line:
SC/ST (Prevention of Atrocities) Act, 1989 - Quashing of proceedings - Petitioner, a cameraman covering Covid-19 vaccination programme, was a stranger to complainant and had no premeditation or intentional caste-based insult - Mere filming of vaccination programme, even if complainant or another lady was captured, would not by itself constitute offence - In absence of material beyond complaint averments, continuation of criminal proceedings held to be abuse of process of law.
Statutory provision(s): Article 226 of the Constitution of India, Section 482 of the Criminal Procedure Code, Sections 3(1)(r), 3(1)(s) of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989, Sections 341, 323, 506, 34 of the Indian Penal Code, 1860
Sri. Manjunath v. State of Karnataka, (Karnataka) : Law Finder Doc Id # 2992787
