A) ABSTRACT / HEADNOTE

The Supreme Court in Batlanki Keshav (Kesava) Kumar Anurag v. State of Telangana & Anr. addressed the maintainability of parallel FIRs alleging offences under Section 376(2)(n) of the Indian Penal Code, 1860 and Section 3(2)(v) of the SC/ST (Prevention of Atrocities) Act, 1989, arising from allegations of sexual intercourse under a false promise of marriage. The appellant sought quashing under Section 482 CrPC, asserting that the FIRs were contradictory, exaggerated, and maliciously filed. The Court observed that the complainant, a highly educated woman, had earlier filed multiple similar complaints against different individuals and that the allegations in the two FIRs could not be reconciled. The omissions in the first FIR, compared with the exaggerated versions in the second, were held to be inherently improbable. The Court also relied on chat transcripts and other documents reflecting manipulative tendencies and vindictive behaviour of the complainant. It was held that continuation of prosecution would amount to abuse of process and a travesty of justice. Accordingly, both FIRs and all proceedings emanating therefrom were quashed. The ruling reinforces judicial scrutiny in cases involving sexual relations under alleged false promises of marriage and clarifies that inherent contradictions, mala fide motives, and misuse of special statutes like the SC/ST Act cannot be ignored.

Keywords: False promise of marriage; Quashing of FIR; Manipulative complainant; Contradictory FIRs; Abuse of process of law; SC/ST (POA) Act; Consent in sexual relations; Vindictive tendency; Judicial scrutiny under Section 482 CrPC.

B) CASE DETAILS

C) INTRODUCTION AND BACKGROUND OF JUDGEMENT

The case revolves around the interplay between false promise of marriage and criminal liability under Section 376 IPC along with invocation of the SC/ST (POA) Act. The appellant was accused by the complainant, a 30-year-old woman, of sexual exploitation under a promise of marriage which he later withdrew. Initially, an FIR was registered under Sections 417 and 420 IPC alleging cheating. Later, another FIR was filed alleging repeated sexual assaults under Section 376(2)(n) IPC and caste-based discrimination under Section 3(2)(v) of the SC/ST Act.

The High Court of Telangana dismissed the appellant’s plea for quashing the second FIR, leading to this appeal before the Supreme Court. The Court’s task was to assess whether the subsequent FIR constituted an abuse of process, especially in view of contradictions with the earlier complaint and the larger factual context.

The judgment situates itself within the broader jurisprudence concerning the misuse of criminal law provisions, particularly in cases where consensual relationships are later projected as instances of sexual assault on the ground of false promise of marriage. Courts have consistently held, as in Pramod Suryabhan Pawar v. State of Maharashtra (2019) 9 SCC 608, that not every breach of a promise to marry constitutes rape; only when the promise is false from inception and consent is obtained through deception does it attract Section 375 IPC. The present case further elaborates on this distinction.

Additionally, the invocation of the SC/ST Act raised questions of mala fide exaggeration, as the caste-based allegations surfaced only in the second FIR and were absent from the first. The Court thus examined whether the criminal proceedings were being weaponised to harass the appellant. This background makes the case a significant addition to the judicial discourse on balancing protection of women’s rights with safeguarding individuals from malicious prosecution.

D) FACTS OF THE CASE

The complainant, through Bharat Matrimony, came into contact with the appellant, who was then residing in the USA. Both families engaged in discussions, and a written agreement was executed where the appellant agreed to marry the complainant. Wedding arrangements, including venue bookings, were initiated. However, disputes arose when the appellant and his mother allegedly delayed and avoided fixing a date for marriage.

On 24 June 2021, the complainant alleged that the appellant compelled her to engage in sexual intercourse under the pretext of marriage. The following day, she lodged a complaint, leading to FIR No. 751 of 2021 under Sections 417 and 420 IPC at Police Station Madhapur. Anticipatory bail was granted to the appellant.

Subsequently, another FIR was filed in Kerala, later transferred to Madhapur as FIR No. 103 of 2022, alleging repeated sexual assaults on 4 May, 11 May, 28 May, and 7 June 2021, and further alleging caste-based rejection under Section 3(2)(v) of the SC/ST Act. This second FIR expanded the allegations significantly beyond the scope of the first.

The appellant approached the High Court under Section 482 CrPC to quash FIR No. 103 of 2022, contending that it was contradictory, mala fide, and based on exaggerations. The High Court refused quashing but directed no coercive action pending investigation.

Before the Supreme Court, the appellant relied on transcripts of conversations and chat records where the complainant allegedly admitted manipulative intentions, including targeting “green card holders” and describing men as “victims.” It was also highlighted that the complainant had filed similar complaints in the past, including against an Assistant Professor at Osmania University.

The Supreme Court was thus called upon to decide whether the continuation of proceedings in FIR No. 103 of 2022 constituted abuse of process.

E) LEGAL ISSUES RAISED

i. Whether the allegations of sexual intercourse under a false promise of marriage in the second FIR constitute a prima facie case under Section 376(2)(n) IPC?
ii. Whether invocation of Section 3(2)(v) SC/ST (POA) Act was justified when no caste-based allegation was made in the first FIR?
iii. Whether filing two contradictory FIRs concerning the same relationship amounts to abuse of process of law?
iv. Whether the High Court erred in refusing to quash the FIR under Section 482 CrPC despite glaring contradictions and mala fide intent?
v. Whether the right to reputation and liberty of the accused under Article 21 of the Constitution was infringed by continuation of such prosecution?

F) PETITIONER / APPELLANT’S ARGUMENTS

The counsel for the appellant submitted that the complainant, despite being a highly educated 30-year-old woman, willingly engaged in consensual sexual relations, which cannot retrospectively be converted into rape charges. It was argued that the first FIR of June 2021 contained only a single allegation of sexual intercourse on 24 June 2021. The omission of multiple prior incidents in that FIR rendered the later allegations in FIR No. 103 of 2022 inherently improbable.

Reliance was placed on Pramod Suryabhan Pawar v. State of Maharashtra and Deepak Gulati v. State of Haryana (2013) 7 SCC 675, where the Court distinguished between breach of a promise to marry and false promise of marriage. The appellant argued that even if he withdrew from the proposed marriage, it did not prove that his initial intent was mala fide.

The appellant also highlighted the complainant’s history of lodging similar complaints, including one against a university professor, which revealed a pattern of vindictive and manipulative behaviour. Chat transcripts, where the complainant admitted using men for personal motives and referred to them as “victims,” further exposed her mala fides.

It was argued that continuation of criminal proceedings would amount to gross abuse of process, as laid down in State of Haryana v. Bhajan Lal (1992 Supp (1) SCC 335), where the Supreme Court held that inherently improbable and mala fide allegations warrant quashing under Section 482 CrPC.

G) RESPONDENT’S ARGUMENTS

The counsel for the State opposed the appellant’s submissions, contending that the allegations of sexual intercourse under a false promise of marriage clearly made out a prima facie case under Section 376(2)(n) IPC. It was urged that the appellant induced the complainant into sexual relations with a fraudulent intent not to marry her and later backed out, thereby attracting the offence of rape.

The State further submitted that since allegations of caste-based rejection were also made, Section 3(2)(v) SC/ST Act was rightly invoked. It was argued that these allegations involve serious offences and should not be lightly quashed at the threshold.

The State stressed that the High Court had already struck a balance by directing investigation without coercive measures and that premature interference by the Supreme Court would obstruct due process.

H) RELATED LEGAL PROVISIONS

i. Section 376(2)(n), IPC – Rape on repeated occasions.
ii. Sections 417 & 420, IPC – Cheating and cheating by dishonestly inducing delivery of property.
iii. Section 3(2)(v), SC/ST (POA) Act, 1989 – Offence committed against a member of SC/ST on the ground of caste.
iv. Section 482, CrPC – Inherent powers of High Court to quash proceedings to prevent abuse of process of law.
v. Article 21, Constitution of India – Right to life and personal liberty, including right to reputation.

I) JUDGEMENT

The Supreme Court held that the allegations in the two FIRs were mutually contradictory and could not be reconciled. It noted that the complainant’s omission to mention multiple alleged sexual assaults in the first FIR rendered the later additions inherently improbable. The Court also observed that the complainant had filed similar complaints against others in the past and her chats revealed manipulative tendencies.

The Court ruled that continuation of prosecution would amount to abuse of process and a travesty of justice. Accordingly, both FIRs and all proceedings were quashed in entirety.

a. RATIO DECIDENDI

The Court reiterated the principle that consent given in a relationship cannot be retrospectively converted into rape unless it is proved that the promise to marry was false from inception. Citing Pramod Suryabhan Pawar and Deepak Gulati, the Court emphasized that mere breach of promise does not constitute rape.

It was held that contradictions between multiple FIRs over the same subject matter destroy the credibility of allegations and justify quashing under Section 482 CrPC. The Court further held that invocation of Section 3(2)(v) SC/ST Act was unjustified since caste-based allegations were absent in the first FIR, and their later introduction was a sheer exaggeration.

b. OBITER DICTA

The Court remarked that educated adults engaging in consensual relationships must bear responsibility for their choices, and criminal law should not be misused to settle personal vendettas. It also stressed that frivolous or vindictive use of special legislations like the SC/ST Act weakens their efficacy in genuine cases.

The Court further observed that judicial intervention is necessary when criminal process is weaponised to harass individuals and that reputation, being a facet of Article 21, deserves protection from malicious prosecutions.

c. GUIDELINES

The Court laid down the following guiding principles:

i. Allegations in multiple FIRs concerning the same subject matter must be scrutinised for inherent contradictions before allowing prosecution.
ii. Delay or omission in disclosing critical allegations in earlier complaints undermines the credibility of subsequent allegations.
iii. Quashing under Section 482 CrPC is justified where allegations are improbable, mala fide, or intended to harass.
iv. Mere breach of promise to marry does not amount to rape unless it is shown that the promise was false from inception.
v. Invoking SC/ST Act provisions without direct nexus to caste-based discrimination amounts to misuse and warrants judicial correction.

J) CONCLUSION & COMMENTS

The decision in Batlanki Keshav Kumar Anurag reinforces the balance between protecting women from sexual exploitation and preventing misuse of criminal law. The Court rightly emphasised that contradictions in multiple FIRs, delay in allegations, and evidence of manipulative behaviour render prosecutions unsustainable. The judgment strengthens jurisprudence on false promise of marriage cases, reiterating that consent in adult relationships cannot be equated with rape unless deception is proved from inception.

The ruling also signals a strong judicial stance against frivolous invocation of the SC/ST Act, thereby protecting its sanctity. It underscores the need for courts to intervene at the threshold in cases where continuation of proceedings would be oppressive and unjust. At the same time, it does not dilute the seriousness of genuine sexual offences but ensures that criminal law is not weaponised for vindictive purposes.

K) REFERENCES

Important Cases Referred
i. State of Haryana v. Bhajan Lal, 1992 Supp (1) SCC 335.
ii. Pramod Suryabhan Pawar v. State of Maharashtra, (2019) 9 SCC 608.
iii. Deepak Gulati v. State of Haryana, (2013) 7 SCC 675.
iv. Uday v. State of Karnataka, (2003) 4 SCC 46.
v. Subhash Kashinath Mahajan v. State of Maharashtra, (2018) 6 SCC 454.

Important Statutes Referred
i. Indian Penal Code, 1860 – Sections 376(2)(n), 417, 420.
ii. Code of Criminal Procedure, 1973 – Section 482.
iii. SC/ST (Prevention of Atrocities) Act, 1989 – Section 3(2)(v).
iv. Constitution of India – Article 21.