List of Current Affairs

Source: Supreme Court

Why in News?

A Division Bench of the Supreme Court of India, comprising Justice Prashant Kumar Mishra and Justice NV Anjaria, in Gunjan @ Girija Kumari and Others v. State (NCT of Delhi) and Another (2026), allowed an appeal and quashed proceedings under the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989 (SC/ST Act), against the appellants who were accused of hurling caste-based abuses against the complainant inside a private residential house. 

• The Court held that since the FIR did not disclose that the alleged incident occurred "in a place within public view" — an essential ingredient of offences under Sections 3(1)(r) and 3(1)(s) of the SC/ST Act — the proceedings against the appellants were unsustainable.

What was the Background of Gunjan @ Girija Kumari and Others v. State (NCT of Delhi) and Another (2026) Case? 

• An FIR was registered against the accused persons on allegations that they attempted to break open the lock of the complainant's house and hurled caste-based slurs — including chura, chamar, harijan, and dirty drain — against him and his wife. The complainant and two of the accused were real brothers belonging to a Scheduled Caste community, while the wives of the accused belonged to non-SC/ST communities. 
• The Trial Court framed charges under Sections 3(1)(r) and 3(1)(s) of the SC/ST Act against one of the accused, along with charges under Section 506 read with Section 34 of the IPC against all the accused. 
• The Delhi High Court declined to interfere with the order framing charges. 
• Before the Supreme Court, the appellants contended that the FIR itself failed to disclose the essential ingredient that the alleged incident occurred "within public view," as mandatorily required under the SC/ST Act.

What were the Court's Observations? 

• On the Essential Ingredient of "Public View": The Court held that to constitute an offence under Sections 3(1)(r) and 3(1)(s) of the SC/ST Act, the act of hurling caste-based abuses must occur at "a place within public view." Even a private place may qualify, but only if the public has access to observe what is taking place there. A residential house, by its very nature, does not satisfy this requirement. 
• On the FIR in the Present Case: The judgment, authored by Justice Anjaria, examined the FIR closely and found that the alleged incident had taken place inside the complainant's residential premises — a location neither exposed to public gaze nor accessible to the public. The Court held that the essential requirement of the offence was conspicuously absent from the FIR. 
• On Quashing of Charges: Since the FIR did not disclose the commission of any offence under the SC/ST Act, the Court allowed the appeal and quashed the proceedings, holding that continuing the prosecution in such circumstances would be unsustainable.

What ST/SC (Prevention of Atrocities) Act, 1989?

About the SC/ST Act:  

• SC/ST Act 1989 is an Act of Parliament enacted to prohibit discrimination against SC & ST communities' members and prevent atrocities against them.  
• The Act was passed in Parliament of India on 11th September 1989 and notified on 30 January 1990.  
• The Act is also a recognition of the depressing reality that despite undertaking several measures, the Scheduled Castes/Scheduled Tribes continue to be subjected to various atrocities at the hands of upper castes.  
• The Act has been enacted keeping in view the express constitutional safeguards enumerated in Articles 15, 17 and 21 of the Constitution of India, 1950 (COI), with a twin-fold objective of protecting the members of these vulnerable communities as well as to provide relief and rehabilitation to the victims of caste-based atrocities.  

SC/ST (Amendment) Act, 2015:  

• This Act was amended in the year 2015 for the purpose of making the act more stringent with the following provisions:  
  • Recognition was given to more instances of atrocities as crimes against SCs and STs.  
  • It added several new offences in Section 3 and renumbered the entire section since the recognized crime almost doubled.  
  • The Act added Chapter IVA Section 15A (the rights of victims and witnesses), and defined dereliction of duty by officials and accountability mechanisms more precisely.  
  • It provided for the establishment of exclusive special courts and special public prosecutors.  
  • In the context of public servants at all levels this Act defined the term willful negligence.  

SC/ST (Amendment) Act, 2018:  

• In the case of Prithvi Raj Chauhan v. Union of India (2020), the Supreme Court upheld the constitutional validity of Parliament’s 2018 Amendment to the Prevention of Atrocities Act. The Salient features of this Amendment Act are as follows:  
  • It added Section 18A to the original Act.  
  • It delineates specific crimes against Scheduled Castes and Scheduled Tribes as atrocities and describes strategies and prescribes punishments to counter these acts.  
  • It identifies what acts constitute “atrocities” and all offences listed in the Act are cognizable. The police can arrest the offender without a warrant and start an investigation into the case without taking any orders from the court.  
  • The Act calls upon all the states to convert an existing sessions court in each district into a Special Court to try cases registered under it and provides for the appointment of Public Prosecutors/Special Public Prosecutors for conducting cases in special courts.  
  • It creates provisions for states to declare areas with high levels of caste violence to be “atrocity-prone” and to appoint qualified officers to monitor and maintain law and order.  
  • It provides for the punishment for willful neglect of duties by non-SC/ST public servants.  
  • It is implemented by the State Governments and Union Territory Administrations, which are provided due central assistance. 

Section 3(1)(r) of the SC/ST Act:  

• Section 3 of this Act deals with punishments for offences atrocities.  
• Section 3(1)(r) states that whoever, not being a member of a Scheduled Caste or a Scheduled Tribe intentionally insults or intimidates with intent to humiliate a member of a Scheduled Caste or a Scheduled Tribe in any place within public view shall be punishable with imprisonment for a term which shall not be less than six months but which may extend to five years and with fine. 

Section 3(1)(s) of the SC/ST Act:

• This provision makes it an offence when a person who is not a member of a Scheduled Caste or Scheduled Tribe abuses any member of a Scheduled Caste or Scheduled Tribe by caste name in any place within public view. 

Source: Supreme Court

Why in News? 

A Division Bench of the Supreme Court of India, comprising Justice J.B. Pardiwala and Justice Ujjal Bhuyan, in Sheikh Abedin v. Iqbal Ahmed & Anr. (2026), dismissed a Special Leave Petition filed by a defendant who had been directed to vacate suit premises on the basis of admissions made by him in criminal proceedings, wherein he acknowledged that he was occupying the property merely as a caretaker under the plaintiff. 

• The Court upheld the concurrent findings of the Trial Court, First Appellate Court, and the High Court, and affirmed that a judgment on admission under Order XII Rule 6 of the Civil Procedure Code, 1908 (CPC) may be founded on admissions made outside the pleadings, including those made in criminal proceedings, so long as such admissions are clear and unequivocal.

What was the Background of Sheikh Abedin v. Iqbal Ahmed & Anr. (2026) Case? 

• The matter arose from a civil suit for mandatory injunction, wherein the plaintiff-respondent sought eviction of the defendant-appellant from the suit premises. 
• In a complaint filed by the appellant, which led to the registration of an FIR, the appellant had admitted that he was the caretaker of the suit property owned by the respondent.  
• The Trial Court relied upon this admission and decreed the suit under Order XII Rule 6 CPC, directing the appellant to vacate the suit property. 
• The decree of the Trial Court remained undisturbed before the First Appellate Court and thereafter before the High Court. Aggrieved by the concurrent findings, the appellant approached the Supreme Court. 
• Before the Supreme Court, the appellant contended that an admission made in criminal proceedings cannot form the basis for passing a judgment against him in civil proceedings under Order XII Rule 6 CPC, as such an admission is made outside the pleadings of the civil suit.

What were the Court's Observations? 

• On the Scope of Order XII Rule 6 CPC: The Court held that the provision does not restrict the court to admissions made only within the pleadings. A decree under Order XII Rule 6 CPC may be passed on the basis of any admission, whether contained in the pleadings or elsewhere — whether in writing or oral — and no particular form of admission is required for this purpose. 
• On the Nature of the Admission Required: The Court reiterated, relying on Uttam Singh Duggal & Co. Ltd. v. United Bank of India, (2000) 7 SCC 120, that the admission on which judgment is claimed must be clear and unequivocal. Such admission may relate to the entire claim in the suit or even to a part of the claim, in respect of which a separate decree may be passed. 
• On the Purpose of Order XII Rule 6 CPC: The Court observed that the purport of the provision is to enable a party to obtain speedy justice to the extent of the relevant admission which, according to the other party's own acknowledgment, he is entitled to. The provision is a procedural mechanism for expeditious disposal where the defendant's own admissions render a full trial unnecessary. 
• On the Facts of the Case: The Court noted that the appellant had unambiguously admitted in the criminal complaint that he was a caretaker of the suit property owned by the respondent. This admission, being clear and unequivocal, was rightly relied upon by the courts below to pass a decree of mandatory injunction directing eviction. The Supreme Court found no ground to interfere with the concurrent findings.

What is Order XII Rule 6 CPC? 

Order XII Rule 6 CPC — Judgment on Admissions 

Bare Provision: 

• Sub-rule (1): Court may make an order or give judgment on admissions of fact made in pleadings or otherwise, whether orally or in writing, at any stage of the suit, on application by any party or suo motu, without waiting for determination of other questions between the parties. 
• Sub-rule (2): Where judgment is pronounced under sub-rule (1), a decree shall be drawn up accordingly, bearing the date of the judgment. 

Key Features: 

• Admissions may be express or implied, written or oral, made before institution of suit, after filing, or during pendency of proceedings. 
• Court's power is discretionary — it shall have regard to such admissions when passing orders. 
• Admission need not be confined to pleadings — it may be made dehors the pleadings, i.e., in any document or statement recorded before the court. 
• Two separate decrees may be passed: one for the admitted claim and another for the non-admitted or contested claim. 
• A decree under this rule may be either preliminary or final. 

Effect of 1976 Amendment: 

• Pre-amendment, Rule 6 allowed judgment on admission only on a party's application. 
• Post-amendment, the court may also act suo motu. 
• Admissions are no longer confined to Order VI Rules 1 and 4 — they are of general application. 

Important Judicial Pronouncements: 

• Uttam Singh Duggal & Co. Ltd. v. United Bank of India (2000): Where a claim is admitted, the court has jurisdiction to enter judgment and pass a decree on the admitted claim. The scope of Order XII Rule 6 should not be narrowed down where a party is entitled to succeed on a plain admission of the opposite party. 
• ITDC Ltd. v. Chander Pal Sood and Son (2000): Rule 6 confers very wide discretion on the court. The word "otherwise" means the court can pass judgment not only on pleadings but also on statements made dehors the pleadings — including any document or statement recorded in court.