Allowed

Smt Bhagyamma D B @ Bhagyalakshmi v. the State of Karnataka by

Karnataka HC16 Sept 2026CRL.P/13189/2025

Case brief

AI extract

What is this about?

The Karnataka High Court quashed criminal proceedings under the SC/ST (Prevention of Atrocities) Act, 1989, holding that alleged caste-based abuse in a private clinic and via WhatsApp messages did not occur in a public place, which is a prerequisite for offences under Sections 3(1)(r) and 3(1)(s) of the Act, as per the Supreme Court's ruling in Hitesh Verma v. State of Uttarakhand.

What did the court decide?

Proceedings in Spl.C. No. 2324/2024 on the file of the Court of LXX Additional City Civil and Sessions Judge and Special Judge, Bengaluru, are quashed.

Smt Bhagyamma D B @ Bhagyalakshmi Vs the State of… — Caste Atrocities | Karnataka HC (2026)

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NC: 2026:KHC:50484 CRL.P No. 13189 of 2025

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HC-KAR

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CNR: KAHC010611532025

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IN THE HIGH COURT OF KARNATAKA AT BENGALURU

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DATED THIS THE 16^TH DAY OF SEPTEMBER, 2026

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BEFORE

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THE HON'BLE MR. JUSTICE SURAJ GOVINDARAJ

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CRIMINAL PETITION NO.13189 OF 2025

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(482(Cr.PC)/528(BNSS))

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BETWEEN:

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SMT. BHAGYAMMA D.B @ BHAGYALAKSHMI W/O RANGANATH R., AGED ABOUT 32 YEARS, R/O NO.108, CHENNANAYAKANA PALYA, NEAR SUBRAMANYA TEMPLE, CHIKKABIDAREKALLU, NAGASANDRA POST, BENGALURU-560 073.

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…PETITIONER

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(BY SRI. GANAPATI S. SHASTRI, ADVOCATE)

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AND:

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THE STATE OF KARNATAKA BY BAGALAGUNTE POLICE STATION, BY SPP, HIGH COURT BUILDING, BENGALURU-560 001.

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SRI. RAMAKRISHNA T.N. S/O NARASIMHAIAH, AGED ABOUT 40 YEARS, R/O NO.03, MUNESHWARA LAYOUT, DODDABIRAKALLU, NAGASANDRA POST, BENGALURU-560 073.

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…RESPONDENTS

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(BY SRI. RANJITH KUMAR N., HCGP., FOR R.1; SRI. A. PUNEETH KUMAR, ADVOCATE FOR R.2 (VC))

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Digitally Signed By: SURAJ GOVINDA RAJ 21/09/2026, 13:40, BENGALURU Verified

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HC-KAR

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NC: 2026:KHC:50484 CRL.P No. 13189 of 2025

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CNR: KAHC010611532025

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THIS CRL.P. FILED UNDER SECTION 482 OF CR.P.C. (U/S.528 OF BNSS), PRAYING TO QUASH THE PROCEEDINGS IN SPL.C.NO.2324/2024 ON THE FILE OF COURT OF LXX ADDITIONAL CITY CIVIL AND SESSIONS JUDGE AND SPECIAL JUDGE, BENGALURU, BY ALLOWING THE ABOVE PETITION IN THE INTEREST OF JUSTICE AND EQUITY.

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THIS PETITION, COMING ON FOR ORDERS, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: CORAM: HON'BLE MR. JUSTICE SURAJ GOVINDARAJ

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ORAL ORDER

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The petitioner is before this Court seeking for the following reliefs:

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a. Call for records and quash the proceedings in Spl.C.No.2324/2024 on the file of Court of LXX Addl. City Civil & Sessions Judge and Special Judge, Bengaluru, by allowing the above petition in the interest of justice and equity.

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A complaint filed by respondent No.2 against the petitioner alleging that the petitioner had used the caste of respondent No.2 and abused respondent No.2, as also sent messages on WhatsApp abusing respondent No.2, pursuant to which an FIR in Crime No.327/2024 was registered by Bagalagunta Police Station. On investigation, a charge sheet had been filed on 15.11.2024. It is challenging the same that the petitioner is before this Court.

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A perusal of the complaint and charge sheet indicates that the alleged abuse of respondent No.2 by the

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Digitally Signed By: SURAJ GOVINDA RAJ 21/09/2026, 13:40, BENGALURU Verified

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HC-KAR

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NC: 2026:KHC:50484 CRL.P No. 13189 of 2025

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CNR: KAHC010611532025

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petitioner is in the clinic of the petitioner and by way of WhatsApp messages. The same is not in any public area attracting the offences under Section 3(1)(r) and 3(1)(s) of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989, as held by the Hon'ble Supreme Court in Hitesh Verma v. State of Uttarakhand & Anr¹

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