'SC/ST Act Misused; Fraud Upon State': Allahabad HC Fines Accused ₹5 Lakh For Manipulating Victim; Orders Refund Of Compensation

Dismissing a criminal appeal filed by 19 accused under Section 14-A (1) of 1989 Act SC/ST Act, a bench of Justice Shekhar Kumar Yadav directed the alleged victims, a Dalit woman and her two daughters-in-law, to refund the entire compensation amount of ₹4.5 lakh received by them from the State Government.

Notably, at the same time, the Court also imposed a cost of ₹5 lakh on the 19 accused-appellants for their role in manipulating the victim and attempting to subvert the course of justice.

"To deter recurrence of such manipulative conduct, a cost of Rs. 5,00,000/- (Rupees Five Lakh only) is imposed upon the appellants. The said amount shall be deposited with the High Court Welfare Fund within twenty days from today", Court's order reads.

Briefly put, the criminal appeal was filed by 19 accused seeking to quash the cognizance and summoning order passed by the Special Judge (SC/ST Act), Prayagraj in connection with a criminal case involving serious charges under Sections 147, 148, 149, 323, 504, 506, 452, and 354(kha) IPC and Section 3(2)(va) SC/ST Act.

During the hearing on November 4, 2025, counsel for the appellants argued that the FIR was lodged on the thumb impression of the complainant.

However, this assertion was categorically denied by the counsel for the complainant, who contended that no such FIR was lodged by the victim.

Noting that the complainant is a woman belonging to the SC community, the Court, apprehended that the applicants might have approached her and exerted undue pressure upon her.

The single judge thus directed the Deputy Commissioner of Police (Yamunapar), the Investigating Officer and the victim herself to appear personally before the Court on November 6, 2025.

Now today, all three [the DCP, the IO and the victim] appeared before the Court and on a pointed query by the Bench, the complainant stated that her thumb impression had been taken on a blank paper.

On the other hand, the Government Advocate produced the case records to show that the FIR had actually been lodged on the basis of a written complaint submitted by the complainant herself.

The GA also informed the Court that the statements of the complainant and her two daughters-in-law were recorded under Section 161 CrPC as well as under Section 164 CrPC, wherein all three had unequivocally supported the prosecution version.

The GA further apprised the bench that all three women had been medically examined and had received ₹1.5 lakh each [totaling ₹4.5 lakh] as compensation under the statutory scheme of the SC/ST Act.

Taking note of these submissions, the Court recorded its dismay over the turn of events as it observed thus:

"The Court finds it deeply disturbing that the complainant now denies having filed the FIR, despite having made statements under Section 164 Cr.P.C. affirming the allegations and having availed of substantial monetary compensation under the statutory scheme meant for genuine victims of atrocities".

"Such conduct prima facie reflects a serious abuse of the process of law and a gross misuse of the benevolent provisions of the SC/ST Act. The sequence of events suggests a deliberate attempt to manipulate the criminal justice process after wrongfully obtaining public funds, thereby committing a fraud upon the State", the Court further observed.

Thus, while dismissing the appeal, the Court took a serious view of the matter and issued the following directions:

1. The victim and her two daughters-in-law are jointly and severally directed to refund the entire ₹4.5 lakh compensation to the competent authority of the State Government forthwith.
2. A cost of ₹5 lakh is imposed on the 19 appellants, to be deposited with the High Court Welfare Fund within twenty days.
3. In case of default, the Registrar General will initiate coercive recovery of the said amount from the appellants in accordance with law.

Importantly, the Court made it clear that its observations should not prejudice the ongoing criminal proceedings.

The Special Judge (SC/ST Act), Prayagraj, has been directed to continue the trial strictly in accordance with law, uninfluenced by the contradictory stand taken by the victim before this Court or by the observations made herein.