Institute of Legal and Management Studies

The Supreme Court on Thursday (May 29) quashed a rape case against a man accused of forcible sexual intercourse on the pretext of a false promise of marriage, noting that the complainant's past conduct was questionable, as her behaviour appeared manipulative and vindictive, including threats of criminal action against the accused and other persons if they refused to marry her.

The bench comprising Justice Vikram Nath and Justice Sandeep Mehta heard the case where the complainant-Respondent no.2 being well-educated and a major had omitted crucial details in the first FIR and then later filed a second FIR alleging multiple incidents of forcible sexual intercourse and caste-based refusal to marry. The offences under the SC/ST Act were also added in the FIR.

After perusing her Chats, the Court noted that the complainant had the tendency to lodge false complaints against other men too, where she mentions that she would irritate her victims to the extent that they dump her, and she could happily start with the next one. She also stated that she was using the accused-appellant. Some of her chats showed that she was "trying to get a green-card holder" and that she needs to “invest on the next victim”.

“These chats depict the stark reality about the behavioral pattern of the de-facto complainant who appears to be having manipulative and vindictive tendency.”, the court said.

“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.”, the court added.

Further, the judgment authored by Justice Nath noted that the complainant's allegation of caste-based offence under the SC/ST Act was untenable as it was introduced later on just to harass the Appellant to invoke harsher penal provisions.

“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 with the de-facto complainant on the ground that she belonged to the Scheduled Castes/Scheduled Tribes community.”, the court said.

Ultimately, the Court found that the continuance of the offence against the Appellant was nothing short of an abuse of process of law, thus, the appeal was allowed, and the pending criminal proceedings stand quashed.

“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.”, the court held.

Case Title: BATLANKI KESHAV (KESAVA) KUMAR ANURAG VERSUS STATE OF TELANGANA & ANR.

Citation : 2025 LiveLaw (SC) 645

Click here to read/download the judgment

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.