The Delhi High Court has denied anticipatory bail to a film director accused of repeatedly raping and blackmailing a woman on the pretext of launching her in the film industry. Justice Girish Kathpalia ruled that granting anticipatory bail in such a case would set a dangerous precedent and send the wrong message to society.
"This is not a case of regular bail sought by the petitioner after his arrest. This is a case of anticipatory bail, sought by a film director, who allegedly committed repeated acts of sexual exploitation against a small-town girl who aspired to be a film heroine. Granting anticipatory bail in such cases would also send very wrong signals across the society, portraying that after exploiting such girls, a person with hands in pocket can go scot-free."
The petitioner, Sanoj Kumar Mishra, a Mumbai-based film director, was accused of luring the prosecutrix through social media platforms like TikTok and Instagram in 2020. He allegedly promised her a role in a movie but instead exploited her physically, blackmailed her with obscene photos, and forced her to undergo multiple abortions.
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Allegations Against the Film Director
According to the FIR filed at Police Station Nabi Karim under Sections 376, 323, 313, 354C, and 506 IPC, the accused established contact with the victim through social media. Initially, they exchanged phone numbers, and in June 2021, he asked her to meet him at Jhansi Railway Station. When she refused due to societal pressure, he threatened to commit suicide, forcing her to comply.
- The next day, he again called her to the railway station and took her to a resort under the guise of having a conversation.
- After dinner, she started feeling dizzy, and upon regaining consciousness around midnight, she found herself naked.
- He informed her that he had taken obscene photographs and videos of her and would make them public if she objected.
- Under continued threats, he allegedly raped her multiple times at different locations while assuring her of a career in the film industry.
- She later moved to Mumbai, believing in his promises, but was physically assaulted and forced to undergo three abortions before being abandoned in February 2025.
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Court’s Reasoning for Denying Bail
During the hearing, the prosecutrix stated that she had no objection to granting anticipatory bail to the petitioner. However, the court was not convinced that her consent was voluntary.
"Just because now, the prosecutrix does not object to the grant of anticipatory bail, the present petition cannot be allowed. The petitioner allegedly clicked obscene videos and photographs of the prosecutrix and threatened to make them public if she did not cooperate. Under these circumstances, I am not satisfied that consent given by the prosecutrix to grant anticipatory bail is a voluntary act of hers."
The prosecution argued that custodial interrogation was necessary to recover the obscene material and investigate the multiple abortions. The court found that the allegations in the FIR were detailed and specific, making it unlikely that they were fabricated.
Case title: SANOJ KUMAR MISHRA VS. STATE GOVT. OF NCT OF DELHI
