The Supreme Court set aside two FIRs filed by a woman against the appellant under charges of rape and caste-based offences, after closely examining the inconsistencies in her statements, prior history of similar allegations, and lack of credible supporting evidence. The Court observed that continuing criminal proceedings in such circumstances would constitute an abuse of legal process and cause unjust harm to the accused.
Brief Facts of the Case
- The complainant and the appellant met on a matrimonial platform and agreed to marry.
- A dispute arose when the appellant allegedly backed out of the marriage, prompting the complainant to file FIRs in two states, alleging sexual exploitation on the basis of a false promise of marriage and caste-based discrimination.
- The appellant submitted evidence including past chat records, call transcripts, and details of an earlier complaint filed by the same complainant against another individual, suggesting a recurring pattern.
- The High Court had earlier refused to quash the FIR; this decision was challenged before the Supreme Court.
Legal Provisions Involved in the Case
- Section 376(2)(n), IPC – Repeated rape
- Section 417, 420, IPC – Cheating and dishonestly inducing delivery of property
- Section 3(2)(v), SC/ST (Prevention of Atrocities) Act – Offences committed on the basis of caste
- Section 482, CrPC – Inherent powers of High Court to prevent abuse of the process of law
Arguments of Petitioner and Respondent
Appellant’s Submissions:
- The relationship was consensual, and there was no deception or coercion.
- Chat transcripts suggested that the complainant had obsessive tendencies and was attempting to control or manipulate the relationship.
- Submitted that the allegations in the second FIR were exaggerated and inconsistent with the earlier FIR.
- Highlighted a previous complaint made by the complainant against another individual under similar circumstances.
Respondent’s Submissions:
- Argued that the accused entered into a sexual relationship with no intention to marry, constituting a false promise.
- Asserted that the caste of the complainant was a reason for refusal to marry, thus attracting provisions under the SC/ST Act.
- Contended that investigation had already led to a chargesheet being filed.
Court’s Observation
- The Court found significant contradictions between the two FIRs filed by the complainant.
- Noted that the complainant was a 30-year-old educated woman and had not reported multiple prior incidents in the first FIR, raising serious doubts.
- Observed that the complainant had previously filed similar allegations against another individual, suggesting a pattern.
- Recorded that chat records indicated the complainant had referred to “trapping” or “manipulating” partners and considered shifting focus to the “next victim.”
- Held that the complaint lacked the foundational elements necessary to substantiate charges under rape or caste-based offence provisions.
Conclusion of the Judgment
The Court quashed FIR No. 751 of 2021 and FIR No. 103 of 2022, along with all connected proceedings. It held that continuation of prosecution in such circumstances would amount to misuse of legal provisions and could not be permitted in the absence of credible, consistent, and prima facie evidence.
Comments from the author of this website
It is increasingly common to see criminal provisions—originally designed to protect genuine victims—being invoked in disputes that stem from failed personal relationships.
In this matter, the complainant, despite being educated and aware, filed multiple FIRs that contradicted each other. What troubles me most is the pattern: not only were there inconsistencies between her statements, but she had also previously filed similar allegations against another man. This isn’t just about one case—it signals a systemic issue.
When a relationship doesn’t work out, criminalizing it—especially using serious charges like rape or caste-based atrocities—can ruin lives. The emotional toll, the damage to one’s career and reputation, and the trauma of navigating a flawed system are immense. Many men do not have the support, resources, or even the vocabulary to defend themselves when accused falsely.
This judgment, to me, reaffirms something we’ve been saying for years—due process matters. A failed relationship is not a crime. Consensual intimacy between adults, when entered without coercion, should not become grounds for criminal prosecution because things didn’t end well.
Final Thoughts
This case is not about denying protection to genuine victims. It is about ensuring that allegations are scrutinized with fairness, and that the criminal justice system is not used as a tool for retaliation or emotional vengeance.
The Court’s decision reflects a careful, fact-based approach—examining evidence, inconsistencies, and past conduct of both parties. It serves as a reminder that gender-neutral scrutiny is vital in criminal proceedings. Emotional narratives must not outweigh facts and context.
For those of us who advocate for balanced laws, this judgment is a step toward that direction. But it also underlines the urgent need for reforms—laws must evolve to prevent misuse without undermining the rights of those they were meant to protect.
Ultimately, justice should not depend on who makes the allegation, but on what the evidence truly shows.
Read Complete Judgement Here