IIT-Kanpur Caste Discrimination Complaint : Supreme Court Favours Conciliation, Suggests Talks Between Dalit Faculty & His Colleagues

“We feel that the continuation of criminal proceedings will be an impediment to restoration of normalcy and bringing cordiality back between the appellant and the respondents in their professional and personal capacities.

We, therefore, at this stage, are not inclined to continue with these proceedings and deem it appropriate to dispose of the same, with a recommendation to the chairman of the Board of Governors to invite the appellant and all the four respondents together and ensure that there are no pending misunderstandings or misgivings between them so as to guarantee professionalism and an ideal academic atmosphere in the institution.”

The bench, while disposing of the appeal, observed that the ‘unfortunate episode’ of the four senior professors allegedly “hurting the sentiments, prestige, and dignity” of the Dalit academician and criticising the originality of his doctoral thesis had compelled him to file a police complaint.

The conduct of the faculty members of a premier institute must be ‘exemplary’ as students follow in their footsteps and there was a solemn responsibility on not only the respondents but also the appellant to “ensure that none of their actions downgraded or demeaned the institution”, the bench said.

"The attribution of allegations and counter-allegations damages the reputation of individuals as well as the institution. We, therefore, impress upon them to ensure that they work together as a team in the best interests of the institution and their students, and do not allow any unfortunate and untoward incidents to occur which might hurt the sentiments, feelings, respect and dignity of each other", the bench observed.

Notably, not only did the senior professors specifically deny their alleged direct or indirect role in connection with the doubts that were created regarding Saderla’s thesis or the social humiliation inflicted on him, but they also pledged before the court “to never do any such thing, or make any comments, which may hurt the sentiments and feelings of the appellant in any manner”.

Saderla, who joined the institute’s aerospace engineering department on January 1, 2018, had filed a complaint with the administration soon after, accusing his colleagues, Chandra Shekhar Upadhyay, Ishan Sharma, Rajiv Shekhar, and Sanjay Mittal of caste-based discrimination and harassment. These charges were reportedly upheld by a three-member panel led by the National Commission for Scheduled Castes, who then directed the IIT Kanpur administration to lodge a complaint against all four under the Scheduled Castes and Scheduled Tribe (Prevention of Atrocities) Act, 1989. However, in the same year, the Allahabad High Court stayed the criminal action against them, stating, inter alia, that issuing such a direction was beyond the scope of the commission’s powers.

In the meantime, the institute formed an inquiry committee headedby a retired judge of the Allahabad High Court that found the Dalit academician’s allegations of harassment at the hands of his four colleagues to be true. Following this, the university board demoted Mittal, Upadhyay, and Shekhar, while Sharma was let off with a warning. Subsequently, on the strength of a first information report registered by Saderla, the four professors were also booked under Section 500 (defamation) of the Indian Penal Code, 1860 as well as the Scheduled Castes and Scheduled Tribe Act. However, in the same year, the high court allowed a writ petition filed by the accused and quashed the FIR. Reports also suggest that the faculty forum rallied behind the four professions and demanded that the institute defend them. “If anyone charges them under the SC/ST Act for carrying out their professional and official duties, it is the responsibility of the institute to defend them in any court or any other place,” the convenor of the forum wrote to the IIT Kanpur director.

In October, the situation took another turn when an anonymous email was sent to several faculty members alleging that portions of his doctoral thesis were plagiarised. Even though the academic ethics cell reportedly found no reason to revoke the thesis after investigating the complaint, the Senate Post-Graduate Committee recommended that the PhD thesis be withdrawn, and a revised version be re-evaluated, in a move that was widely criticised as indicating a vendetta against the young Dalit academician for the success of his complaint.

Eventually, the matter was referred to a three-member committee which concluded that Saderla’s thesis referred to material that was ‘common knowledge’ in his field of study and recommended appending a brief corrigendum. The assistant professor accepted the suggestion and submitted a corrigendum, which was subsequently approved by the board. Putting an end to the controversy, the board resolved that his doctoral thesis on aerodynamic parameter estimation would be read along with the corrigendum and Saderla was awarded a doctorate degree.

The apex court bench noted, “There is no remaining doubt regarding the genuineness of the PhD thesis, and the degree that was awarded to the appellant. His dedication, hard work and deep research on the subject stand duly recognised.”

Case Title

Subrahmanyam Saderla v. Chandra Shekhar Upadhyay | Criminal Appeal No. 460 of 2023 arising out of Special Leave Petition (Criminal) No. 3663 of 2020

Citation : 2023 LiveLaw (SC) 126

For Petitioner(s) Mr. Ashok K. Gupta, Sr. Adv. Ms. Sunita Sharma, AOR Ms. Nishi Prabha Singh, Adv. Mr. Abhishek Gupta, Adv. Ms. Ikshita Singh, Adv. Mr. Kapil Raghav, Adv. Mr. Dishant Bhati, Adv. Ms. Tanya, Adv.

For Respondent(s) Mr. Siddharth Luthra, Sr. Adv. Mr. Prashant Kumar, Adv. Mr. Avneesh Tripathy, Adv. Mr. Smarhar Singh, AOR Mr. Ankit Goel, AOR

Scheduled Caste and Scheduled Tribes (Prevention of Atrocities) Act 1989 - Supreme Court refuses to interfere with HC order quashing FIR lodged by a Dalit IIT faculty member against his colleagues alleging caste-based harassment- Court favours a conciliatory approach and urges the Chairman of Board of Governor to invite the complainant and the accused for talks- Court observes allegations and counter-allegations damage the repute of a premier institution like IIT- Court impresses upon them to ensure that they work together as a team in the best interests of the institution and their students, and do not allow any unfortunate and untoward incidents to occur which might hurt the sentiments, feelings, respect and dignity of each other- Court says the continuation of criminal proceedings will be an impediment to restoration of normalcy and bringing cordiality back between the appellant and the respondents in their professional and personal capacities.

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