The Patna High Court has set aside a trial court’s order taking cognizance of offences under the Indian Penal Code and the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989 (“SC/ST Act”). The appeals arose from a school-workplace dispute in Gaya district. The High Court examined the complaint history, the police’s final report, independent administrative inquiries, and the governing legal tests for quashing. Finding the prosecution to be driven by mala fides and unsupported by the record, the Court quashed the cognizance order as against the two appellants: the head of the local school and a senior director stationed in New Delhi.

Simplified Explanation of the Judgment

This case began with a complaint by a Class-IV staff member of a private school in Sherghati, Gaya. She alleged that the head of the school subjected her to harassment, including caste-based abuse, coercion to perform menial tasks, and inappropriate advances, and that a senior official in the school’s managing committee told her to “obey” the head. Based on a Magistrate’s direction under Section 156(3) of the Code of Criminal Procedure (CrPC), the police registered an FIR for offences under Sections 354, 341, 504, and 506 read with Section 34 of the IPC and under Section 3(1) provisions of the SC/ST Act.

During investigation, the police submitted a “final form” (closure report) declaring the case false. Notably, before and around the time of the FIR, the head of the school had initiated verification of the staff member’s school leaving certificate (SLC). According to the appellate record, the verification response indicated that the SLC was fake—not issued by the school named in that certificate. The school’s regional office sought an explanation, and the administration flagged to the District Magistrate a threat by the complainant and two other contract workers to implicate the school in a false SC/ST case. Separately, the District Magistrate reportedly conducted an inquiry at the request of the Scheduled Castes Commission and communicated that the complaint’s allegations were found false.

Despite the investigation result and the administrative inquiry, the Special Judge (SC/ST), Gaya, disagreed with the police closure and, on 16.03.2020, took cognizance against the two accused for offences under Sections 354 and 354-D/34 IPC and under Section 3(1)(r)(s)(h)(j)(w)(ii) of the SC/ST Act, and issued process.

The two accused filed criminal appeals before the Patna High Court challenging this cognizance order. The High Court heard both appeals together, as they arose from the same order.

In allowing the appeals, the High Court applied the well-known principles for quashing criminal proceedings under Article 226 of the Constitution and Section 482 CrPC, as summarized by the Supreme Court in State of Haryana v. Bhajan Lal (1992 Supp (1) SCC 335). Those principles, often called the “Bhajan Lal categories,” guide courts on when to step in to prevent abuse of process—such as where the allegations, even if taken at face value, do not disclose any offence; where they are inherently improbable; or where proceedings are manifestly attended with mala fides.

Key points from the Court’s reasoning include:

• Mismatch between allegations and material on record: The complaint narrative—particularly regarding the director stationed in New Delhi—did not disclose how there could have been any interaction that satisfied the ingredients of the alleged offences. There was neither physical nor virtual interaction pleaded that would make out caste-based abuse or sexual harassment attributable to the director. This strongly supported the absence of a prima facie case against that appellant.
• Independent findings undermining the complaint: The police investigation concluded the case was false. An administrative inquiry by the District Magistrate, communicated to the SC Commission, reportedly reached the same conclusion. While a Magistrate can disagree with a police closure report and take cognizance, such disagreement must be grounded in material indicating a prima facie offence. The High Court found the trial court’s cognizance—despite these contrary findings—insufficiently supported.
• Context suggesting ulterior motive (mala fides): The sequence of events showed that the head of the school initiated verification of the complainant’s SLC, which was allegedly found to be fake. According to the appellate material, threats of false implication under the SC/ST Act were contemporaneously reported to the administration. The High Court inferred that the prosecution was set in motion not to redress a genuine atrocity, but to counter the consequences of the SLC verification process. This fit the Bhajan Lal categories (1), (5), and (7)—no prima facie offence made out; allegations inherently improbable; and proceedings manifestly mala fide.
• Overbreadth of invoked SC/ST provisions: The complaint lacked specifics tying the statutory elements—such as intentional insult or intimidation with intent to humiliate in public view—to concrete, verifiable conduct, and the alleged acts against the director were particularly unsubstantiated.

On this analysis, the High Court quashed the Special Judge’s order dated 16.03.2020 “qua the above-named appellants,” i.e., the head of the school and the director. Both criminal appeals were allowed, and the matter was closed against them.

Significance or Implication of the Judgment

• Reinforcement of Bhajan Lal safeguards: The decision underscores that criminal law is not a tool for settling employment disputes or shielding against disciplinary verification (like SLC checks). Courts will apply the Bhajan Lal tests to weed out prosecutions that appear retaliatory or unsupported by material.
• Measured application of the SC/ST Act: While the SC/ST Act is a vital protective legislation, the Court emphasizes that its invocation must be anchored in specific, prima facie facts. Where the complaint is vague, improbable, or contradicted by objective inquiries, courts can intervene at the cognizance stage to prevent abuse.
• Protection for supervisory officials with no nexus: Senior officials geographically and functionally removed from day-to-day operations cannot be prosecuted in the absence of concrete allegations showing their direct participation in the alleged offences.
• Administrative inquiries matter: Reports from district authorities and police final forms, though not binding on a Magistrate, carry weight. If a Magistrate departs from those findings, there must be clear reasons based on the record. Otherwise, higher courts may step in.
• Workplace governance takeaways: School and institutional administrators should document verification steps and correspondence (e.g., SLC checks). Proper records can be decisive in demonstrating bona fide actions when allegations surface later.

Legal Issue(s) Decided and the Court’s Decision with reasoning

• Whether cognizance could be sustained despite a police final report declaring the case “false.”
  Decision: No, on these facts. The Special Judge’s cognizance lacked a firm material foundation and ignored consistent findings from the police and the District Magistrate’s inquiry. The High Court quashed cognizance as an abuse of process.
• Whether the allegations disclosed the statutory ingredients of IPC Sections 354/354-D and SC/ST Act provisions against both appellants.
  Decision: No. As to the director, there was no pleaded interaction making out any ingredient of the offences. As to the head of the school, the allegations, viewed with the contemporaneous context (SLC verification sequence and administrative findings), did not meet the Bhajan Lal threshold for allowing prosecution to proceed.
• Whether the case fell within the Bhajan Lal categories for quashing.
  Decision: Yes. The Court relied on category (1) (no prima facie offence even if allegations accepted), category (5) (allegations inherently improbable), and category (7) (proceedings manifestly mala fide).

Judgments Relied Upon or Cited by Court

• State of Haryana v. Bhajan Lal, 1992 Supp (1) SCC 335 — guiding categories for quashing criminal proceedings at the threshold.

Case Title

Satyendra Prasad Yadav v. State of Bihar & Anr.; Dr. Nisha Peshin v. State of Bihar & Anr. (heard and decided together)

Case Number

Criminal Appeal (SJ) No. 782 of 2022 (with) Criminal Appeal (SJ) No. 1000 of 2021
(Arising out of SC/ST P.S. Case No. 45 of 2019, District Gaya)

Citation(s)

2025 (1) PLJR 308

Coram and Names of Judges

Hon’ble Mr. Justice Chandra Shekhar Jha

Names of Advocates and who they appeared for

• For the appellants: Mr. Anil Kumar Singh, Advocate; Mr. Sanjay Kumar Singh, Advocate; Mrs. Bela Singh, Advocate
• For the State: Mr. Sadanand Paswan, Special Public Prosecutor
• For the informant: Mr. Mithilesh Kumar Singh, Advocate

Link to Judgment

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