In Brief
The appellants were charged under IPC sections 323, 504, and 506 for assault. More than two years later, the National Commission for Scheduled Castes directed police to add charges under the SC/ST (Prevention of Atrocities) Act, Section 3(1)(x). The Supreme Court held that no external agency can dictate criminal investigation—it remains within police's exclusive jurisdiction. Since the original FIR contained no allegation of caste-based abuse and the statutory ingredients were unsubstantiated, the supplementary charge-sheet was an abuse of process. The Court allowed the appeal and quashed the supplementary charges, clarifying that High Courts can quash charges in part under Section 482 CrPC.
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