Landmark Ruling: Supreme Court Clarifies Grounds for Conviction under SC/ST Act in Outraging Woman's Modesty Cases

In a significant legal development, the Supreme Court has provided crucial insights into the conviction criteria under Section 3(1)(xi) of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act 1989. According to the court, an essential condition for sustaining the conviction is that the act of outraging the modesty of a woman must be committed on the grounds of caste.

The court emphasized the language of Section 3(1)(xi), highlighting that the offense should be perpetrated against a person belonging to Scheduled Castes or Scheduled Tribes, intending that it was done based on caste considerations.

Quoting the section, the Court stated: “Whoever, not being a member of a Scheduled Caste or a Scheduled Tribe assaults or uses force to any woman belonging to a Scheduled Caste or a Scheduled Tribe with the intent to dishonor or outrage her modesty shall be punishable…”

The Bench of Justices B.R. Gavai, Prashant Kumar Mishra, and Sandeep Mehta set aside the findings of the High Court and the Trial Court. They underscored, “A plain reading of the section makes it clear that the offense of outraging modesty should be committed with the intention that the victim belonged to the Scheduled Caste category.”

Citing the precedent of Masumsha Hasanasha Musalman Vs. State of Maharashtra 2000(3) SCC 557, the court further elucidated on the requirement for caste-based intent.

In the case under consideration, the allegation was that the accused appellant attempted to outrage the modesty of the complainant, engaged for household chores in his house. However, the court observed that even from the highest allegations, the offending act was not committed with the intention of targeting a person from the Scheduled Caste.

In a concise summary, the accused-appellant, initially convicted under various sections of the Indian Penal Code and Section 3(1)(xi) of the SC/ST Act, appealed the decision. The High Court upheld the SC/ST Act conviction, leading to a subsequent appeal to the Supreme Court.

Setting aside the conviction under the SC/ST Act, the Supreme Court asserted, “The conviction of the accused appellant for the offense under Section 3(1)(xi) of the SC/ST Act was otherwise also not sustainable on merits.” Consequently, the appellant is acquitted of the charge under Section 3(1)(xi) of the SC/ST Act in the case of Dashrath Sahu versus State of Chhattisgarh.