Courts Should Invoke Section 182 IPC Against Those Filing False FIRs Under SC / ST Act Solely For Securing Compensation: Allahabad HC
The Allahabad High Court observed that the Courts to invoke Section 182 IPC to hold accountable those individuals, who file false FIRs under the SC-ST (Prevention of Atrocities) Act solely for the purpose of securing compensation.
The Court said that the weaponization and misuse of provisions intended to protect vulnerable groups who have historically faced discrimination not only undermines the very spirit of these laws but also hampers the progress toward genuine equality.
The Court was hearing an Application under Section 482 Cr.P.C. seeking to quash the charge sheet as well as the entire proceeding arising out of Case under Sections 504, 506, 323 I.P.C. and Sections 3(1)da, 3(1)dha S.C./S.T. Act as well as stay the further proceeding of the aforesaid case, pending before the Additional District & Session Judge on the basis of compromise.
The bench of Justice Manju Rani Chauhan observed, “At the same time, to maintain balance and deter the abuse of this special legislation, courts should invoke the legal recourse available under Section 182 of the I.P.C. to hold accountable those individuals, who file false FIRs solely for the purpose of securing compensation.”
Advocate Ashutosh Upadhyay appeared for the Appellant and Advocate Rajesh Kumar Singh appeared for the Respondent.
The Court noted that even after asking a proper query to the opposite party as to why he was not returning the compensation amount, he could not give a proper answer and tendered an apology admitting that, under pressure from the villagers, he had lodged a false FIR.
The Court observed, “When legal safeguards are exploited for personal or financial gain, it dilutes their effectiveness and erodes public trust in the justice system. Such actions divert attention and resources away from legitimate cases where real victims need protection and justice.
“Ultimately, this misuse threatens to perpetuate inequality, as it distorts the purpose of these protective measures, which are crucial for addressing systemic injustices and creating a truly equitable society. For true equality to be realized, these legal provisions must be applied with integrity, ensuring they serve those genuinely in need and not those seeking to exploit the system for unjust gains.”, the Court observed further.
The Court said that to effectively address the misuse of the SC/ST Act and ensure that its provisions are not exploited, several measures should be implemented such as, “First, a thorough pre-registration verification process should be established, requiring law enforcement to assess the credibility of complaints before filing FIRs. This could involve mandatory mediation sessions, where parties can attempt to resolve disputes amicably before resorting to legal action. Second, training programs should be conducted for police officers and judicial officials to help them recognize signs of potential misuse and to ensure that they approach cases with sensitivity and awareness of the implications. Third, a dedicated oversight body could be established to monitor complaints under the SC/ST Act, investigating patterns of misuse and providing recommendations for action. Finally, public awareness campaigns should be launched to educate communities about the Act's purpose and the consequences of filing false claims, thereby fostering a culture of integrity and accountability.”
Accordingly, the Court quashed the chargesheet and the subsequent proceedings.
Finally, the Court allowed the Application.
Cause Title: Vihari v. State of. U.P. (Neutral Citation: 2024:AHC:153816)
