Casteist Slurs by Client in Lawyer's Office Constitute 'Public View' Under SC/ST Act: Karnataka High Court

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Published 31 October 2026

Case: Smt. B.L. Sujatha v. Sri. M.N. Prakash
Court: High Court of Karnataka
Bench: Justice S. Rachaiah
Citation: 2024 LiveLaw (Kar) 200
Decided: 22 May 2024
Statutes: Scheduled Castes and the Scheduled Tribes (Prevention of Atrocities) Act, 1989 — s.3(1)(r)
Code of Criminal Procedure, 1973 — s.482
Source: LiveLaw

Bottom Line Up Front (BLUF)

In Smt. B.L. Sujatha v. Sri. M.N. Prakash, 2024 LiveLaw (Kar) 200, the Karnataka High Court held on May 22, 2024, that a client hurling casteist slurs at a lawyer in her office, witnessed by her staff, amounts to an offence committed within 'public view' under Section 3(1)(r) of the Scheduled Castes and the Scheduled Tribes (Prevention of Atrocities) Act, 1989.

Ratio Decidendi · Legal Principle Established

An offence under Section 3(1)(r) of the Scheduled Castes and the Scheduled Tribes (Prevention of Atrocities) Act, 1989, is committed within 'public view' if the casteist abuse occurs in a place accessible to the public or where members of the public are present and witness the act, even if it is a private office, provided others are present.

Practice & Procedural Impact for Advocates

Advocates should advise clients that private offices, when staff or other individuals are present, may be considered 'public view' for offences under the SC/ST Act. Litigants must be aware that casteist remarks made in such settings can attract criminal liability under the Act. Counsel should ensure proper documentation of witnesses present during such incidents.

Key Legal Takeaways

1A private office can be a 'public view' under the SC/ST Act if others are present.
2The presence of staff or other individuals makes casteist abuse in a private setting actionable.
3The Karnataka High Court interpreted 'public view' broadly to include places accessible to the public.

The Legal Issue

The Karnataka High Court addressed whether casteist slurs hurled by a client at a lawyer in her private office, witnessed by her staff, would constitute an offence committed within 'public view' as defined under Section 3(1)(r) of the Scheduled Castes and the Scheduled Tribes (Prevention of Atrocities) Act, 1989 (SC/ST Act). The petitioner sought to quash criminal proceedings initiated against him under Section 482 of the Code of Criminal Procedure, 1973 (CrPC), arguing that the incident did not occur in a public place.

Court's Reasoning

Justice S. Rachaiah, presiding over the case, rejected the petitioner's argument. The Court referred to the Supreme Court's decision in *Swaran Singh v. State through Standing Counsel*, which clarified that 'public view' does not necessarily mean a public place. Instead, it refers to an act that is 'visible and audible to the public'. The Karnataka High Court reasoned that a lawyer's office, while private, is a place where clients and staff are present, making it accessible to a section of the public. Since the lawyer's staff witnessed the casteist abuse, the act was deemed to have occurred within 'public view'. The Court emphasized that the intent of the SC/ST Act is to protect members of Scheduled Castes and Scheduled Tribes from such atrocities, and a narrow interpretation of 'public view' would defeat this purpose.

What Follows

The Karnataka High Court dismissed the petition, thereby allowing the criminal proceedings against the client to continue. The Court directed the trial court to proceed with the case in accordance with the law. This decision clarifies that even in a private setting like an office, if casteist remarks are made in the presence of others, it can attract the provisions of the SC/ST Act, specifically Section 3(1)(r).