SANJAY SANYAL v. THE STATE OF MAHARASHTRA AND ANR
Departmental Disciplinary Proceedings Excluded from "Other Legal Proceedings" under Atrocities Act; FIR Quashed as Abuse of Process.
Court: Bombay High Court
Citation: 2026:BHC-AS:9202-DB
Decision Date: 20-02-2026
List of Laws
The Scheduled Castes and the Scheduled Tribes (Prevention of Atrocities) Act, 1989; Bharatiya Nagarik Surakhsa Sanhita, 2023; Service Law - Disciplinary Proceedings; Criminal Procedure - Quashing of FIR
- Facts: The Respondent No. 2, a Medical Officer at Nuclear Power Corporation of India Limited (NPCIL), was placed under suspension in 2013 following reports of serious misconduct, including using offensive language and obstructing the Acting Medical Superintendent. Formal disciplinary proceedings were initiated, which eventually resulted in a penalty of salary reduction, a decision upheld by both Appellate and Review authorities. In 2016, shortly before the retirement of the Chairman (Petitioner No. 1), the Respondent filed an FIR alleging that these disciplinary actions were a "counterblast" to his whistleblowing activities regarding corruption and were motivated by his status as a member of a Scheduled Caste. He invoked Section 3(1)(viii) [now 3(1)(p)] of the Atrocities Act, claiming the Petitioners instituted false and malicious legal proceedings against him.
- Procedural Posture: The Petitioners, being the Chairman and General Manager (H.R.) of NPCIL, approached the Bombay High Court through Writ Petitions seeking to quash the FIR registered at Tarapur Police Station, District Palghar.
- Issue: Whether departmental disciplinary proceedings conducted by an employer against an employee fall within the ambit of "other legal proceedings" under Section 3(1)(p) of the Scheduled Castes and the Scheduled Tribes (Prevention of Atrocities) Act, 1989?
- Holding: No, departmental and administrative proceedings do not constitute "legal proceedings" for the purpose of the Atrocities Act.
- Reasoning: The Court reasoned that the term "legal proceedings" in Section 3(1)(p) must be interpreted "ejusdem generis" with the preceding words "suit" and "criminal". This implies proceedings conducted in a court of justice or a tribunal to acquire a right or enforce a remedy. Referring to Supreme Court precedents, the Court held that "legal proceedings" are distinct from "departmental" or "administrative" proceedings. Furthermore, to attract the Act, there must be evidence that the proceedings were instituted "falsely, maliciously or vexatiously" specifically because the victim belongs to a Scheduled Caste. In this case, the proceedings were based on documented misconduct and had attained finality through the disciplinary process. The FIR was deemed an abuse of process and a tool for harassment by a disgruntled employee.
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