Employer–employee relationship is not a crime: Nagpur Bench of Bombay high court quashes atrocities case against IIMC-Amravati director

NAGPUR: The Nagpur Bench of the Bombay High Court on Tuesday quashed an atrocity case against the regional director of the Indian Institute of Mass Communication (IIMC) at 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 filed 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 the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989.

The court ruled that the 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 Judge observed. “The person who is head of institute has his own way to carry out the administrative work. The head of the institute is always of the opinion that all the staff should work as per his guidance for the progress of the institution.”

The court added that enforcing discipline within an organisation cannot be treated as a criminal act. “There is nothing wrong on the part of such authority if he wants to put the staff in discipline to make progress of the institute. For such conduct of the authority, he cannot be blamed, nor can any criminal offence be registered against him,” the judgment stated.

The case originated from a complaint filed by a contractual assistant lecturer working at IIMC, who alleged that he was harassed and insulted by the director because he belonged to a Scheduled Caste. 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 2-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 that the Atrocities Act is intended to protect members of historically marginalised communities from humiliation and discrimination, but cautioned against misuse of the 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 that the accused intentionally insulted the complainant on the ground of caste.

Holding that continuation of the proceedings would amount to “an abuse of the process of law,” the court quashed the atrocity case along with the chargesheet and related criminal proceedings pending before the sessions court against the petitioner.

Key takeaways from the HC ruling

• Quashed criminal proceedings against Anil Kumar Saumitra, IIMC Regional Director, Amravati.
• Allegations were made under the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act.
• No evidence showed that the accused intentionally insulted the complainant on basis of caste.
• Witness statements did not support claims of caste-based abuse.
• An internal inquiry committee recorded that no direct caste-based remarks were made.
• Employer-employee relations are delicate, and administrative discipline cannot be treated as a criminal offence.
• Proceedings were held to be an abuse of the process of law.
• The chargesheet and atrocity case were quashed.