The Supreme Court of India delivered a significant judgment in Criminal Appeal No. 2622 of 2024 (Shajan Skaria vs. State of Kerala) concerning the applicability of anticipatory bail under the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989 (SC/ST Act). The appeal was filed by Shajan Skaria, an editor of the online news channel "Marunadan Malayali," challenging the denial of anticipatory bail by the High Court of Kerala. The case centered on alleged caste-based remarks in a video posted by the appellant. The judgment explored critical issues like the interpretation of Sections 3(1)(r) and 3(1)(u) of the SC/ST Act and the prerequisites for granting anticipatory bail.

1. Introduction to the Case

• Overview of the case background.
• Brief details about the parties involved, including the appellant Shajan Skaria and the complainant.

2. Facts of the Case

• The appellant posted a video making allegations against the complainant, a member of the Scheduled Caste Pulaya community.
• The complainant claimed that the video ridiculed him based on his caste.

3. Legal Issues Raised

• Whether the content in the video violates Sections 3(1)(r) and 3(1)(u) of the SC/ST Act.
• Whether anticipatory bail can be granted despite the bar under Sections 18 and 18-A of the SC/ST Act.

4. Interpretation of Legal Provisions

• Detailed discussion on the interpretation of Sections 3(1)(r) and 3(1)(u) of the SC/ST Act.
• Analysis of the statutory bar on anticipatory bail under Sections 18 and 18-A of the Act.

5. Judicial Precedents and Evolution of Anticipatory Bail

• Key Supreme Court judgments cited regarding anticipatory bail under special statutes like the SC/ST Act.

6. Supreme Court’s Analysis

• Consideration of whether the FIR or complaint discloses a prima facie offense under the SC/ST Act.
• Examination of the "intent to humiliate" as a critical factor in determining culpability under Section 3(1)(r) of the Act.

7. Conclusion and Decision

• The Supreme Court’s decision on granting anticipatory bail.
• The broader implications of the judgment for similar cases under the SC/ST Act.