Nagpur: The Nagpur bench of Bombay High Court on Tuesday quashed a case under Atrocities Act against the regional director of Indian Institute of Mass Communication (IIMC), Amravati, observing that administrative decisions taken by the head of an institution to enforce discipline cannot, by themselves, amount to a criminal offence.Justice Pravin Patil allowed a criminal application by Anil Kumar Saumitra, regional director of the institute’s western region campus, and set aside the chargesheet and proceedings pending before the additional sessions judge in Amravati under provisions of Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989.The court ruled allegations against the petitioner did not disclose any caste-based insult or intimidation required to constitute an offence under the Act. “The relationship between employer and employee is delicate. The head of an institute has his own way to carry out administrative work and is of the opinion that staff should work as per his guidance for progress of the institution,” the judge observed.The court added that enforcing discipline within an organisation cannot be treated as a criminal act. “There is nothing wrong on part of the authority to discipline the staff. For such conduct, he cannot be blamed, nor can criminal offence be registered against him,” the judgment stated.The case originated from a complaint filed by a contractual assistant lecturer working at IIMC, Amravati, who alleged he was harassed and insulted by the director because he belonged to the Scheduled Caste category. Based on the complaint, an FIR was registered at Frezarpura police station in Amravati in February 2022, and a chargesheet was later filed under the Atrocities Act.A two-member fact-finding committee constituted by the institute also examined the matter and recorded that no direct caste-based remarks were made by the director. Justice Patil observed the Atrocities Act is intended to protect members of historically marginalised communities from humiliation and discrimination, but cautioned against misuse of law. He said offences under the Act arise only when insults or intimidation are specifically linked to the victim’s caste.After examining the complaint, witness statements, and the committee report, the court concluded that no material existed to establish the accused intentionally insulted the complainant on the ground of caste.Holding that continuation of proceedings would amount to “abuse of the process of law,” the court quashed the case under the Atrocities Act along with the chargesheet and related criminal proceedings pending before sessions court against the petitioner.
