DELHI HIGH COURT ON AIIMS SC/ST ACT HARASSMENT CASE: INITIAL COMPLAINT CRUCIAL, LATER ADDITIONS CANNOT REVIVE CASE

1. FACT OF THE CASE

The appellant, a doctor at AIIMS, filed an appeal under Section 14A(1) of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989. She challenged the order of the Special Court (Additional Sessions Judge, Saket), which had discharged two respondents—senior faculty members—for alleged offences under the SC/ST Act and the Indian Penal Code (IPC). The case arose from incidents of alleged caste-based humiliation, harassment, and intimidation at AIIMS, culminating in the registration of an FIR in 2020.

2. ISSUE BEFORE THE COURT

The primary issue before the Delhi High Court was whether the Special Court had erred in discharging respondents 2 and 3 of offences under the SC/ST Act and IPC, and whether there was enough prima facie material to frame charges against them.

3. CONTENTIONS BY THE PETITIONER

The appellant argued that the trial court wrongly assessed evidence at the stage of charge. She contended that her subsequent statements under Section 164 CrPC elaborated upon earlier complaints and could not be disregarded merely for being improvements. She emphasized that the incidents occurred in the OPD in public view, thus fulfilling the requirement of the SC/ST Act. She also relied on Supreme Court precedents to argue that minor discrepancies between FIR and later statements cannot be grounds for discharge.

4. CONTENTIONS BY THE RESPONDENTS

The respondents argued that the FIR was delayed and the initial complaint dated 16.03.2020 did not mention casteist remarks. They claimed the allegations were afterthoughts meant to falsely implicate them. Witnesses examined during investigation did not support the allegation of casteist remarks, and the requirement of “public view” was not satisfied. They maintained that the appellant had herself behaved improperly and that no offence under the SC/ST Act was made out.

5. COURT OBSERVATIONS

The Court noted that the appellant’s first written complaint made no mention of casteist slurs, which only appeared in later versions. The absence of such crucial allegations in the initial complaint raised doubts about their veracity. It further observed that the requirement under Section 3(1)(r) and (s) of the SC/ST Act—that the insult must be caste-based and in public view—was not satisfied. The Court also found contradictions between statements and concluded that the alleged conduct, at best, reflected workplace disputes rather than caste-based humiliation.

6. RELEVANT CASE LAW & LAW DISCUSSION

The Court discussed precedents such as:

• Ramesh Chandra Vaishya v. State of Uttar Pradesh (2023): held that caste-related remarks must be clearly outlined in FIR/chargesheet.
• Shajan Skaria v. State of Kerala (2024): clarified that insult must be specifically intended to humiliate due to caste identity.
• Deep Bajwa v. State (Delhi HC, 2004): emphasized that deficiencies in an initial complaint cannot later be supplied through supplementary statements.

It was reiterated that mere workplace quarrels or use of abusive language do not fall under the SC/ST Act unless explicitly caste-related and in public view.

7. COURT DIRECTIONS/JUDGMENT

The Delhi High Court upheld the trial court’s decision. It ruled that no prima facie case was made out against respondents 2 and 3 under the SC/ST Act or IPC. However, it confirmed that respondent no.4 (a guard) would face trial for offences under Sections 341 and 354A IPC for allegedly restraining and groping the appellant. Thus, the appeal was dismissed.

8. EXPLANATION OF COMPLEX TERMS

• Prima facie case: A case that, on first impression, appears to have sufficient evidence to proceed to trial.
• Public view (under SC/ST Act): For an offence to attract provisions, the caste-based insult or humiliation must occur in a place visible to others, not in private.
• Discharge: A decision by the court that no sufficient ground exists to proceed with charges against the accused.

9. TRIAL COURT/SESSION COURT OBSERVATION/DECISION

The trial court had discharged respondents 2 and 3 of all offences, finding insufficient evidence of caste-based remarks or intimidation. It only directed charges to be framed against respondent no.4 under Sections 341 and 354A IPC. The High Court agreed with this reasoning and dismissed the appeal.

DATE OF DECISION

22.08.2025

CASE NUMBER

CRL.A. 1145/2024