New Delhi: The Delhi High Court has quashed an FIR and the subsequent proceedings under the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989, emphasizing that welfare legislation should not be misused for ulterior motives.
Delhi High Court Ruling on SC/ST Act: A Landmark Judgment Against Misuse
Justice Dinesh Kumar Sharma delivered the judgment in petitions seeking to quash FIR No. 04/2007 registered at Sarojini Nagar Police Station and related proceedings, including a summoning order from December 2010.
The case involved allegations by Dr. Yadu Lal against senior doctors Dr. A.K. Singh, Dr. Manoj Kumar, and Dr. Deepak Chaudhary of the Central Institute of Orthopaedics at Safdarjung Hospital. The complainant alleged caste-based discrimination and harassment affecting his professional standing.
SC/ST Act Misuse: Delhi HC Emphasizes Fair Implementation in Caste-Based Cases
The court observed that the dispute stemmed from a December 2003 order restricting the handling of arthroscopic equipment to specific doctors. This led to a series of complaints, investigations, and committee formations spanning two decades.
Justice Sharma noted, “The courts must be cautious that such legislation, which is enacted with social welfare in mind, should not be misused. Such legislation should be implemented with purity and for the right purpose, ruling out any misuse for ulterior motives.”
The court found that multiple inquiry committees, including one headed by AIIMS doctors, had identified deficiencies in Dr. Lal’s professional conduct. The National Commission for Scheduled Castes had previously dismissed similar allegations of caste-based discrimination.
In its analysis, the court determined that the complaint failed to establish the essential elements required under Section 3(1)(ix) of the SC/ST Act. The court concluded that the proceedings appeared “to be rooted in professional rivalry rather than caste-based victimization.”
Senior Advocate Ravi Sikri and Advocate Ashok Arora appeared for the petitioners, while Advocate T.R. Naval represented Dr. Yadu Lal. The State was represented by APP Pradeep Gahalot.
Case Title: Deepak Chaudhary & Ors vs State & Anr
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