In a striking order delivered on 22 September 2025, the Supreme Court set aside a Madhya Pradesh High Court ruling and quashed an FIR accusing a Jabalpur municipal employee of rape on the pretext of marriage. The bench of Justice Sanjay Karol and Justice Nongmeikapam Kotiswar Singh noted unusual delays and a pattern suggesting the case may have been filed out of personal grudge.
Background
The appellant, Surendra Khawse, worked as an Assistant Revenue Inspector in Suhagi Municipal Corporation. The complainant, a computer operator and a married woman with a child, alleged that Khawse forced intimacy on 15 March 2023 after promising marriage. According to the FIR, the relationship continued until April before he allegedly backed out. But the Supreme Court record shows a different sequence. Khawse had already complained to police and municipal authorities in April and July 2023, alleging harassment, threats of suicide, and a false implication warning. A show-cause notice was even served on the complainant about her conduct- weeks before she filed her FIR in August 2023.
Court’s Observations
The bench observed, “The FIR was lodged four months after the alleged incident and only after the employer issued a show-cause notice. This leaves open a gaping possibility that the complaint was an afterthought and a vehicle for vengeance.”
Citing the landmark State of Haryana v. Bhajan Lal case and later rulings, the judges stressed that courts must look beyond the written words of a complaint when there is evidence of malicious intent. “In frivolous or vexatious proceedings, the Court owes a duty to look into many other attending circumstances… and read in between the lines,” the order quoted from an earlier Supreme Court precedent.
Decision
Finding the circumstances “manifestly attended with mala fide,” the Supreme Court quashed the FIR and chargesheet under Sections 376 and 376(2)(n) of the Indian Penal Code. It held that continuing the trial would amount to abuse of the judicial process.
“The appeal is allowed,” the bench concluded, setting aside the Madhya Pradesh High Court’s January 2025 refusal to intervene. Any pending applications were closed with this decision.
Case: Surendra Khawse v. State of Madhya Pradesh & Anr.
Date of Judgment: 22 September 2025