Lucknow Advocate gets 7-year jail term for filing a false case under SC/ST Act, had previously filed 10 similar cases: Exclusive details from the Court judgment

On 2nd April, a special SC/ST court in Lucknow sentenced a man named Sahdev to seven years in prison for filing a false case under the SC/ST Act. Additionally, a fine of ₹2,01,000 was also imposed. Sahdev was accused of filing a false case against a man named Satyanarayan, who was already in judicial custody on the date of the incident mentioned in the FIR in connection with another case.

Justice Vivekanand Sharan Tripathi held Sahdev guilty of misusing the provisions of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act to settle a personal land dispute. OpIndia accessed the FIR and relevant court documents linked to the case.

Details of the FIR

On 12th April 2024, Advocate Sahdev approached Gazipur Police Station, Lucknow North, to file a complaint against Satyanarayan, Sanjay, and a few unnamed persons. Based on his complaint, an FIR was registered under Section 392 of the Indian Penal Code (IPC) and Section 3(2)(v) of the SC/ST Act.

In his complaint, Sahdev, an advocate by profession, claimed that Satyanarayan and his son Sanjay orchestrated a robbery with the help of unidentified goons. He claimed that at around 6 PM on 16th March 2023, near the Munshi Pulia police outpost in Lucknow, a group of criminals forcibly snatched ₹20,000 in cash and his mobile phone. He alleged that the assailants were acting on the instructions of the two main accused in the case.

He stated that he immediately informed the Munshi Pulia police outpost about the robbery, but the police there redirected him to the Indiranagar police station, citing jurisdictional issues. At Indiranagar station, he was advised to send a complaint via post to the SHO, which he did on 23rd December 2023.

He claimed that despite sending the complaint to both the SHO and the Commissioner of Police, no action was taken. He further claimed that he did not receive any copy of the FIR or any update on the progress of the investigation. Alleging negligence and complicity on the part of the concerned police officers, he approached the court seeking directions to register the FIR.

The court took note of his application, and the FIR was eventually registered based on the order.

Final report submitted by the police

On 5th March 2025, the Special SC/ST Court accepted the final report submitted by the police on 23rd May 2024 in the case. The report unequivocally concluded that Sahdev’s complaint against Satyanarayan and his son Sanjay was not only fake but also stemmed from a long-standing land dispute between the parties.

Mobile data and lack of eyewitnesses contradict Sahdev’s claims

During the investigation, the police relied on technical and scientific evidence, which included the mobile phone location data of the accused. The police mentioned in the final report that both Satyanarayan and Sanjay were located in Nawabganj, Barabanki, at the time of the alleged robbery. This ruled out their physical presence at the scene where Sahdev claimed the incident had happened.

Independent witnesses did not support Sahdev’s narrative. Statements collected by the investigating officer failed to corroborate the version of events presented by the complainant. The police noted that Sahdev was given the opportunity to submit any new evidence in his protest application filed on 28th February 2025, but he did not.

Sahdev’s protest filled with civil grievances, not criminal substance

In his protest application, Sahdev portrayed Satyanarayan as a hardened conspirator and land mafia figure. He accused Satyanarayan of defrauding him of ₹25 lakh through a forged land deal in Ismailganj. He further claimed that Satyanarayan had used a fake sale deed to sell the land which he had purchased.

He further claimed that despite a High Court order dated 29th January 2024 and a prior order by the SC/ST Court dated 15th September 2021, the accused neither returned his money nor compensated him with an alternate plot, resulting in a total loss of ₹1 crore.

However, the investigating officer observed that it was a civil matter concerning land ownership and money recovery, which provided no grounds for a criminal case under the SC/ST Act or for robbery. The protest application filed by the complainant was seen as an attempt to exert undue pressure and revive settled land disputes through criminal litigation.

Allegations of coercion dismissed by court

Sahdev further claimed that the police had taken his signatures on plain paper under duress and prepared statements as per their own convenience. He alleged that his statements were manipulated and that the police had tried to protect the accused. However, the court rejected these claims for want of evidence.

Interestingly, Sahdev went on to accuse Sanjay of being a habitual criminal, just like his father. He said Sanjay was part of a larger gang that regularly updated him about local incidents and argued that no robber carries a phone while committing a robbery—hence, mobile location data should not be trusted. The court termed these arguments speculative and lacking legal weight.

Ultimately, the police concluded that Sahdev’s complaint was filed with malafide intent, aimed at harassing the accused due to prior animosity. The final report categorically stated that the entire case was manufactured to settle a personal score over land.

Citing lack of supporting evidence, the absence of any credible witness, and the exculpatory nature of mobile location records, the final report recommended that the case be closed.

Judgment in the case

In its judgment, the court cited verses 14 and 18 from Chapter 8 of the Manusmriti, which state, “यत्र धर्मों हाधर्मेण सत्यं यत्रातृतेन च। हन्यते प्रेक्षमाणानां हतास्तत्र सभासद्ः।” It means, “The court (assembly, council, parliament) where evil overrules virtue—truth and honesty—there the members of the council or court are destroyed due to the sin they have committed by permitting this.”

And “पादोअधर्मस्य कर्तारं पादः साक्षिणमृच्छति । पादः सभासदः सर्वान्पदों राजानमृच्छति।” It means, “Each of the doers of the crime, the witnesses in favour of the doer, the judges, council members or jury who pass judgment in favour of the guilty, and the king—all receive one fourth of that sin.”

Another verse quoted by the court read, “अभियोक्ता न चेद्रूयाद् बध्यो दण्डयच्श धर्मतः । न चेत्त्रिपक्षत्प्रब्रूयाद्धर्म प्रति पराजित ।।”, which means, “If the plaintiff fails to produce a witness and explain his stand, he deserves to be prosecuted and punished. If the accused fails to reply to the satisfaction of the court, he is considered guilty and deserves to be convicted.”

Justice Vivekanand Sharan Tripathi, in the judgment, held that the complaint lodged by Sahdev was completely false and fabricated, with an intent to harass the accused through misuse of the stringent provisions of the SC/ST (Prevention of Atrocities) Act. The court observed that the entire sequence of events, starting from the complaint to the FIR registration, was a malicious attempt to implicate the accused and his son due to a pre-existing land dispute.

One of the most crucial observations made by the court was that the prime accused, Satyanarayan, was in judicial custody at the time. The court observed, “The offence claimed by the complainant to have occurred on 16.03.2023 was registered with deep malice against the accused Satyanarayan, whereas the accused Satyanarayan was in district jail from 13.08.2021 to 12.04.2023.”

This finding effectively dismantled the very foundation of the claims laid down by Sahdev against Satyanarayan and his son. Notably, Satyanarayan was supposed to be released from jail on 12th April 2023 but he could not present bail and he was still in judicial custody on the day of incident. The court observed it was not possible for him to commit the crime while being in prison.

The court further highlighted that the FIR was backed by a false affidavit, and such conduct was not only a criminal misuse of judicial machinery but also a blatant abuse of laws meant to protect the marginalised.

The court also commented on the broader trend of repeated fake cases filed under the SC/ST Act by the complainant. It noted that Sahdev had previously lodged around ten such cases against various individuals, all of which were either dismissed or ended with final reports declaring them baseless. The court pointed out that Sahdev misused his position as an advocate to exploit the protective mechanisms of the law and tried to settle personal vendettas under the guise of caste-based victimisation.

Sentencing

Considering the offence to be serious, the court imposed strict punishment. Sahdev was held guilty under Section 182 and Section 211 of the IPC, which deal with providing false information with intent to cause a public servant to use their lawful power to the injury of another, and with making a false charge of an offence with intent to injure.

Under Section 182, he was sentenced to six months of rigorous imprisonment and a fine of ₹1,000. Under Section 211, he was sentenced to seven years of rigorous imprisonment and a fine of ₹2,00,000. The sentences are to run concurrently.

Justifying the quantum of punishment, Justice Tripathi said that filing a false FIR under the SC/ST Act not only causes irreparable harm to the falsely accused but also dilutes the credibility of the legislation intended to protect the genuinely oppressed. The court further stated that the role of Sahdev as a legal practitioner made his offence more grievous, as he was expected to uphold the integrity of the legal process, not misuse it for settling personal vendettas.

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