Administrative Enquiry Mandatory Before SC/ST Act Action Against Public Servants: Supreme Court

The Supreme Court has held that an administrative enquiry is mandatory before initiating proceedings against a public servant under the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989, and quashed proceedings against Tamil Nadu's Deputy Superintendent of Police and a Sub Inspector under the stringent law.

A Bench of Justices J B Pardiwala and K Vinod Chandran allowed an appeal filed by Jananipriya and another, noting that the special court had directed registration of an FIR without an administrative enquiry, contrary to the proviso to Section 4 of the SC/ST Act.

Why did the Supreme Court quash the proceedings under the SC/ST Act?

Court held that since the mandatory administrative enquiry contemplated under the proviso to Section 4 of the SC/ST Act had not been conducted, there was no reason for the proceedings to continue.

The appellants were proceeded against under Section 18A of the Act. Based on an order passed by the First Additional District and Sessions Judge (PCR), Tiruchirappalli, Tamil Nadu, an FIR was registered on December 18, 2025 at Puthanatham police station, Trichy district, under Section 4 of the SC/ST Act and Sections 161A and 167 of the Indian Penal Code.

How did the dispute arise?

A complaint was filed under the SC/ST Act against two persons. The Sub Inspector conducted a preliminary enquiry and found the case to be false, with the allegations having arisen only to counter a civil dispute.

The Deputy Superintendent of Police approved the preliminary enquiry conducted by the Sub Inspector and no FIR was registered.

The complainant then approached the special court under Section 156(3) of the Code of Criminal Procedure, 1973, [corresponding to Section 175(3) of the BNSS] following which the matter was forwarded to the police.

The complainant subsequently filed another petition before the special court alleging dereliction of duty under Section 4 of the SC/ST Act. This led to the special court directing registration of an FIR, which was challenged before the high court.

After the high court declined to interfere, the appellants approached the Supreme Court.

What did the appellants argue before the Supreme Court?

The appellants' counsel relied on the Supreme Court's decisions in Dr Subhash Kashinath Mahajan v State of Maharashtra (2018), Union of India v State of Maharashtra (2020) and Prithvi Raj Chauhan v Union of India & Ors (2020).

It was argued that although Dr Subhash Kashinath Mahajan had been reviewed in Union of India v State of Maharashtra, the decision in Prithvi Raj Chauhan specifically held that Section 18A of the SC/ST Act had to be read in accordance with the law laid down in Lalita Kumari v Government of Uttar Pradesh (2014).

The State, however, argued that the decisions relied upon by the appellants were no longer relevant since Section 4 had been incorporated into the SC/ST Act in 2016 and Section 18A in 2018, before the alleged offence of non-registration of the FIR took place.

The State contended that an FIR ought to have been registered, particularly in a sensitive matter involving allegations of atrocities against a member of a Scheduled Caste.

It also pointed out that although the proviso to Section 4 had been held to be mandatory by a coordinate Bench of the Supreme Court in State of GNCT of Delhi v Praveen Kumar alias Prashanth (2024), further directions could be considered in the present case.

The State counsel submitted that since no administrative enquiry had been conducted, the matter could be remanded to the special court, which was authorised to take cognizance of offences under the SC/ST Act, with a direction to obtain an administrative enquiry report.

What did the Supreme Court hold on the administrative enquiry?

The Bench noted that the special court itself had directed registration of the FIR without an administrative enquiry being conducted.

"We notice that in the present case, the special court itself had directed registration of an FIR without an administrative inquiry having been conducted," Court said.

Court further noted that although an interim order had stayed the investigation in the matter, it did not prevent the State from carrying out an administrative enquiry.

However, the Bench declined to remand the matter to the special court for obtaining an administrative enquiry report at this stage.

"We are of the opinion that at this juncture, there is no requirement to remand the matter to the special court for obtaining an administrative inquiry report from the competent authority," Court said.

The Bench held that since the mandatory requirement of an administrative enquiry under the proviso to Section 4 had not been complied with, there was no reason to continue the proceedings.

The Supreme Court accordingly quashed the FIR registered on December 18, 2025 at Puthanatham police station, Trichy district, along with all further proceedings, and directed that no further proceedings be taken on the same.

Case Title: Jananipriya Vs Gandhi & Ors

Bench: Justices J B Pardiwala and K Vinod Chandran

Date of Judgment: September 10, 2026