Punjab & Haryana High Court Dismisses Appeal Against Acquittal in SC/ST Act Case; Holds Failure to Prove Caste-Based Motive and Unexplained Injuries on Accused Fatal to Prosecution

Case Name: Satpal v. Ajay and Others

Date of Judgment: 13 January 2026

Citation: CRA-AS-40-2025

Bench: Hon’ble Mrs. Justice Sukhvinder Kaur

Held: The Punjab and Haryana High Court dismissed the complainant’s appeal against acquittal and upheld the judgment of the trial court, holding that the prosecution failed to prove its case beyond reasonable doubt. The Court held that where the incident arises out of a version and cross-version, injuries on the accused remain unexplained, and the aggressor cannot be clearly identified, the accused are entitled to benefit of doubt. The Court further held that for attracting Section 3(2)(v)(a) of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989, it must be proved that the offence was committed solely on the ground that the victim belonged to a Scheduled Caste, which was not established in the present case.

Summary: The appeal was filed by the complainant challenging the judgment passed by the Additional Sessions Judge, Jind, whereby respondents No.1 and 2 were acquitted of offences under Sections 323, 341 read with Section 34 IPC and Section 3(2)(v) of the SC/ST Act. The prosecution case was that the complainant Satpal was allegedly assaulted with lathis by the accused Ajay, his son Rahul, and his wife Poonam due to previous enmity.

During trial, the prosecution examined nine witnesses, including the complainant and his wife. The medical evidence established that the injuries suffered by the complainant were simple in nature. However, evidence also emerged that accused Shakuntala @ Poonam had sustained injuries on the same date, which were not explained by the prosecution. The Investigating Officer admitted that on verification, it was found that the complainant had entered the house of the accused and a cross FIR had been registered against him. The complainant was subsequently acquitted in the cross case.

The defence examined DW-1 Kusum Lata, who deposed regarding the complainant’s alleged misconduct and prior incidents involving molestation complaints. The Court found that this testimony, coupled with medical evidence of injuries on the accused, rendered the prosecution version doubtful. The Court held that when both sides sustain injuries and the prosecution fails to explain injuries on the accused, it becomes unsafe to rely upon the prosecution case.

With respect to the offence under the SC/ST Act, the Court held that mere proof that the complainant belonged to a Scheduled Caste was insufficient. Relying on the Supreme Court judgment in Khuman Singh v. State of Madhya Pradesh, the Court reiterated that it must be established that the offence was committed specifically on the ground of the victim’s caste, which was not proved in the present case.

The Court further reiterated settled law that an appeal against acquittal stands on a different footing from an appeal against conviction, and interference is warranted only where findings are perverse or manifestly illegal. No such infirmity was found in the trial court’s judgment.

Decision: The appeal was dismissed. The judgment passed by the trial court acquitting the accused was upheld.