On May 29, the Supreme Court of India quashed a rape case filed against a man accused of engaging in forcible sexual intercourse under a false promise of marriage. The Court’s decision came after careful examination of the complainant’s past behaviour, which was found to be manipulative and vindictive, including threats of criminal action against the accused and others if they refused to marry her.
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The bench comprising Justice Vikram Nath and Justice Sandeep Mehta noted that the complainant, a well-educated major, had initially omitted key details in the first FIR and later filed a second one alleging multiple incidents of forcible sexual intercourse and caste-based refusal to marry. Offences under the SC/ST Act were also added later.
The Court reviewed the complainant’s chats, which revealed her tendency to file false complaints. In her messages, she mentioned irritating her victims until they left her, and then moving on to the next target. One chat even revealed her interest in finding a green-card holder and “investing in the next victim.”
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"These chats depict the stark reality about the behavioral pattern of the de-facto complainant who appears to be having manipulative and vindictive tendency." — Supreme Court.
The Court concluded that the accused was justified in backing out from the proposed marriage, given the complainant’s aggressive and obsessive nature.
"Thus, in our opinion, the accused appellant was absolutely justified in panicking and backing out from the proposed marriage upon coming to know of the aggressive sexual behaviour and the obsessive nature of the de-facto complainant." — Supreme Court.
Justice Nath’s judgment also addressed the complainant’s later inclusion of caste-based allegations under the SC/ST Act, calling it an untenable claim meant to harass the accused.
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"Hence, even assuming that the accused appellant retracted from his promise to marry the complainant, it cannot be said that he indulged in sexual intercourse with the de-facto complainant under a false promise of marriage or that the offence was committed by him on the ground that she belonged to the Scheduled Castes/Scheduled Tribes community." — Supreme Court.
The Court found the entire case to be an abuse of legal process, describing the allegations as fabricated and malicious.
"The impugned FIR No. 103 of 2022 is nothing but a bundle of lies full of fabricated and malicious unsubstantiated allegations levelled by the complainant. The facts on record clearly establish the vindictive and manipulative tendencies of the complainant and these aspects have a great bearing on the controversy." — Supreme Court.
As a result, the Court allowed the appeal and quashed all criminal proceedings against the accused.
Case Title: BATLANKI KESHAV (KESAVA) KUMAR ANURAG VERSUS STATE OF TELANGANA & ANR.
Appearance:
For Petitioner(s) :Mr. Gagan Gupta, Sr. Adv. Mr. Kuldeep Jauhari, Adv. Mr. Sahil Ahuja, Adv. Mr. Anubhav Tyagi, Adv. Mr. Satish Kumar Tripathi, Adv. Mr. Prashant Joshi, Adv. Mr. Amish Aggarwala, AOR
For Respondent(s) : Mr. Kumar Vaibhaw, Adv. Ms. Devina Sehgal, AOR Mr. Yatharth Kansal, Adv.
