Online Classes
Kiran v. Rajkumar Jivraj Jain & Anr (2025) – Supreme Court Latest Case on SC/ST Act
The Supreme Court of India in the case of Kiran v. Rajkumar Jivraj Jain & Anr (2025) reaffirmed the strict bar on granting Anticipatory Bail for offenses under the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989.
The Case and the Ruling
The case arose from a complaint filed by Kiran, a member of the Matang Scheduled Caste community, against Rajkumar Jivraj Jain and others. Kiran alleged that the accused had used casteist slurs, assaulted, and threatened him and his family for not voting for a particular candidate in the assembly elections.
• Additional Sessions Judge: Denied anticipatory bail, finding that the First Information Report (FIR) prima facie disclosed offenses under the SC/ST Act.
• High Court: Granted anticipatory bail, viewing the case as politically motivated and exaggerated.
• Supreme Court: Set aside the High Court’s order, calling it a “manifest error.” The Court emphasized that Section 18 of the SC/ST Act explicitly excludes the application of Section 438 of the Code of Criminal Procedure (Cr.P.C.), which deals with anticipatory bail.
Key Takeaways from the Judgment
1. Strict Bar on Anticipatory Bail
Section 18 of the SC/ST Act creates an absolute bar against granting anticipatory bail when a prima facie case is made out from the allegations in the FIR.
2. Purpose of the Bar
The Court reiterated that this provision is constitutional and seeks to protect vulnerable communities from intimidation and harassment by those accused of committing atrocities.
3. No Mini-Trial at Bail Stage
The Supreme Court criticized the High Court for conducting a “mini-trial” by evaluating witness statements and evidence at the bail stage. The Court clarified that at this stage, the judiciary should only determine if a prima facie case exists based on the FIR—without delving into the merits of the evidence.
4. Narrow Exception
While the bar is strict, the Court acknowledged a limited exception: anticipatory bail may be granted if it is evident that the allegations are “devoid of prima facie merit” and no offense under Section 3 of the Act is made out.
Conclusion
This judgment strengthens the protection available to victims under the SC/ST Act and reinforces the principle that anticipatory bail should not be used to undermine the legislative intent of safeguarding marginalized communities.