Supreme Court Quashes Two FIRs, Holds Allegations Were Fabricated and Constituted Abuse of Process

A bench of Justices Vikram Nath and Sandeep Mehta heard the appeal against the Telangana High Court's December 13, 2022 order rejecting a petition under Section 482 CrPC seeking quashment of FIR No. 103 of 2022 registered at Madhapur Police Station, Cyberabad, under Section 376(2)(n) IPC and Section 3(2)(v) of the SC/ST (Prevention of Atrocities) Act. The appeal arose from allegations that the accused induced sexual intercourse on the false promise of marriage and later resiled, and challenged the High Court's refusal to quash the FIR.

The Court allowed the appeal and quashed FIR No. 103 of 2022, FIR No. 751 of 2021 and all consequential proceedings. The Court found that "there is no material what to say of prima facie material on record to substantiate the allegations of cheating or sexual intercourse under a false promise of marriage against the accused appellant" and recorded that the two FIRs contained "inherent contradictions" which could not be reconciled. The Court, in its reasoning, observed: "Upon appreciating the facts and circumstances narrated above and having given thoughtful consideration to the allegations as set out in the FIR and the chargesheet placed on record by the accused appellant, we find that there is no material what to say of prima facie material on record to substantiate the allegations of cheating or sexual intercourse under a false promise of marriage against the accused appellant. The allegations levelled in FIR No. 751 of 2021, dated 29th June, 2021, and the impugned FIR No. 103 of 2022 are at great variance and the inherent contradictions in the two reports over the same subject matter cannot be reconciled." The Court further described the impugned FIR as "nothing but a bundle of lies full of fabricated and malicious unsubstantiated allegations" and held that allowing prosecution to continue would be "a travesty of justice".

Background

The dispute originated when the de-facto complainant alleged that after an earlier complaint she filed, an agreement was reached at Madhapur Police Station that the accused would marry her and register the marriage, and a written agreement was signed. The complainant later alleged that the accused and his mother evinced reluctance, induced sexual intercourse without intending marriage, and later pressured her to withdraw earlier complaints. FIR No. 751 of 2021 (dated June 29, 2021) was registered at Madhapur for offences under Sections 417 and 420 IPC; a subsequent FIR (No. 103 of 2022, dated February 1, 2022) was lodged after a complaint forwarded from Kozhikode alleging multiple incidents of forcible sexual intercourse and caste-based discrimination, leading to charges under Section 376(2)(n) IPC and the SC/ST(POA) Act.

The accused sought quashment under Section 482 CrPC. The High Court declined the prayer but directed the investigating officer in FIR No. 103 of 2022 to conclude investigation without taking coercive steps and observed that the accused should cooperate with investigation. On appeal, the Supreme Court recorded that the police had submitted a closure report in FIR No. 751 of 2021 and a chargesheet was filed in FIR No. 103 of 2022. The accused placed on record call transcripts and photographs suggesting the complainant suffered from obsessive-compulsive disorder and exhibited manipulative behaviour; the records also reflected earlier similar complaints lodged by the same complainant in 2019. The State opposed quashment, asserting mala fide conduct and the seriousness of sexual assault allegations. After evaluating contradictions between the two FIRs, contemporaneous chat transcripts where the complainant referred to manipulative intentions and attempts "to get a green card holder," and the investigative material, the Court concluded that the allegations did not have even prima facie substantiation and amounted to an abuse of process. The appeal was allowed and both FIRs and consequential proceedings were quashed; pending applications stood disposed of.

Case Details: Case No.: Criminal Appeal No. 2879 of 2025 (Arising out of SLP (Crl.) No. 3316 of 2023); Citation: 2025 INSC 790 Case Title: Batlanki Keshav (Kesava) Kumar Anurag v. State of Telangana & Anr. Appearances: For the Petitioner(s): [Counsel names not specified in the reported judgment] For the Respondent(s): [Counsel names not specified in the reported judgment]