AUTHOR NAME- Snehil Singh, B.A. L.L.B, Fifth Year.
NAME OF INSTITUTION: Babu Banarasi Das University, Lucknow
Citation: [2025] 7 S.C.R. 242: 2025 INSC 790 | Case Type: Criminal Appeal |
Date of Judgement: 29 May 2025 | Judgment by: Justice Vikram Nath & Justice Satish Chandra Sharma |
Petitioner: Batlanki Keshav (Kesava) Kumar Anurag | Respondent: State of Telangana & Another |
Disposal: Criminal Proceedings & FIRs quashed under CrPC Section 482. | Order/ Judgement: Appeal Allowed, FIRs quashed under CrPC Section- 482 |
FACTS:
The facts of the case are described under-
Batlanki Keshav Kumar Anurag who is the Appellant was connected with the de-facto complainant through an online matrimonial portal. He has basically signed a written agreement to marry and register it via a Arya Samaj. On June 2021 the appellant has said that the consensual sexual intercourse was done with the complainant at her house but after some time she has ceased engagement and ceased communication which delayed the dates of citing ritual of marriage. On June 29, 2021 the complainant has basically lodged an FIR No. 751 of 2021 Under the IPC Section- 417 and 420 for cheating and fraud. After few times she has lodged a second FIR on February 1,2022 alleging that multiple rape under IPC 376(2)(n) and caste-based atrocity (SC/St act 3(2)(v)). But the appellant has successfully quashed the FIRs in High court Under CrPC 482 (Dec 13,2022), But the state has appealed that the decision were ultimately reversed on this appeal before High Court.
ISSUE RAISED:
- Were there sufficient prima facie grounds to sustain allegations of rape under false promise of marriage?
- Was the addition of multiple alleged rapes and caste-based offence merely an escalation of earlier cheating allegations?
- Did the complainant’s conduct—including previous complaints and chat records—undermine her credibility?
- Did proceeding with prosecution constitute an abuse of due process under CrPC Sec- 482?
RULE OF LAW:
- CrPC- 482 empowers courts to quash criminal proceedings that constitute an abuse of process or are manifestly unjust (Bhajan Lal principles).
- Under IPC- 376(2)(n) and SC/ST Act- 3(2)(v), alleged rape under false promise and caste-based atrocity require credible prima facie evidence.
- Bench considered digital evidence (chat logs), prior complaints, and internal contradictions as relevant at the quashing stage.
REASONING:
The Supreme Court has found several inconsistencies in the allegations of the complainant. Initially in the first FIR, she only mentioned a single incident of wrongdoing with her. But after some time in the later FIR she has suddenly mentioned that the appellant has done multiple rape before the first incident. The court has noted that none of them were mentioned earlier and also there was no significant time gap between the two complaints. But these sudden changes in the FIRs has created a doubt about there truthfulness and might they were fabricated. The Supreme Court has also taken a close look of the chat between both of the parties of case. There the court found out that the complainant was speaking in a manipulative manner by saying that “invest on the next victim” and she is showing interest in men with the green cards. These facts along with the previous filed a similar FIR against another man in 2019, which has led court to believe that she had a pattern of making such complaints for personal reasons rather than seeking justice. Later the court has also noted that the complainant has also made an allegation of caste based abuse was also introduced in the second FIR, there the court also mentioned that there was no direct link between the alleged sexual misconduct and any caste-based motive and there was also no clear justification for it also. The court also addressed the issue of consent that both of the parties of the case were well educated and they have consensual sexual intercourse with each other. The law does not consider it rape when someone backs out of a marriage after consensual intimacy, unless it can be clearly shown that the person had never intended to marry in the first place. Considering all these points, the Court concluded that continuing with the criminal proceedings would be unfair and an abuse of the judicial process. Therefore, they used its powers under Section 482 of the Criminal Procedure Code to quash both FIRs.
HELD:
The Supreme Court has basically quashed both of the FIRs – 751/2021 and 103/2022 in the earnest by saying that the “The FIR is nothing but a bundle of lies… fabricated and malicious unsubstantiated allegation.” The bench has also reaffirmed that mere withdrawal from the marriage after consensual intercourse does not constitute rape under doctrine of false promise. The court has mentioned that there was abuse of sensitive rape provision(rape, SC/ST act) was noted and court emphasized wider implications- which has been done in order to prevent misuse of criminal laws while safeguarding genuine complaints.
BIBLIOGRAPHY:
Case name- Batlanki Keshav (Kesava) Kumar Anurag v. State of Telangana & Anr. (Criminal Appeal No. 2879 of 2025)[1].
For the full Document, click the link mentioned: https://scr.sci.gov.in//scrsearch/tmp/588a7f0c5feca467036e4f5a426f625549efab708a61fb499d709b71ceb25e231752571386.pdf[2]
[1] [2025] 7 S.C.R. 242: 2025 INSC 790.
[2] Supreme Court Report, https://scr.sci.gov.in/scrsearch/ (last visited July 5, 2025).