BATLANKI KESHAV (KESAVA) KUMAR ANURAG V. STATE OF TELANGANA & ANR 2025 INSC 790:

DATE: 29/05/2025

COURT: Supreme Court of India

BENCH: Justice Vikram Nath and Justice Sandeep Mehta

FACTS:

The de-facto complainant, i.e., the second respondent, filed a complaint in which she alleged that she had previously lodged a complaint against the accused appellant. During the inquiry into that initial complaint, the appellant, accompanied by his mother, appeared at the police station. In the presence of the Inspector of Police, a resolution was reached between the parties whereby the appellant agreed to marry the de-facto complainant and register the marriage formally. However, subsequent events indicated that both the appellant and his mother began to display hesitation and reluctance toward proceeding with the agreed marriage. In the FIR registered in 2021, it was also alleged that the appellant coerced the complainant into engaging in sexual intercourse, despite having no genuine intention of solemnizing the marriage as promised.

In a subsequent FIR, the complainant asserted that her acquaintance with the appellant began through a matrimonial website while he was residing in the United States of America. According to her allegations, both parties agreed to marry, and during this period, the appellant forced her into a sexual relationship against her consent. Later, he outright refused to marry her, citing her lower caste background as the reason. Based on these allegations, a case was registered against the appellant under Section 376(2)(n) of the Indian Penal Code (IPC) and Section 3(2)(v) of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989.

Challenging the proceedings, the accused appellant filed a petition under Section 482 of the Criminal Procedure Code (CrPC) seeking to quash the case. However, the High Court declined to intervene at that stage and directed the Investigating Officer to continue with the investigation. Aggrieved by the High Court's refusal to quash the proceedings, the appellant approached the Supreme Court, seeking appropriate relief.

ISSUES:

The key issues presented in this case revolved around whether the continuation of criminal proceedings against the accused appellant, based on FIRs No. 103 of 2022 and No. 751 of 2021, constituted a misuse of the legal process. The appellant contended that the allegations made by the complainant were fabricated, vindictive, and unsubstantiated, amounting to a malicious attempt to harass him. The Court was required to assess whether the FIRs and the subsequent proceedings were grounded in genuine grievance or were being misused to settle personal scores, thereby amounting to a travesty of justice and abuse of the judicial process.

JUDGEMENT WITH REASONING:

The Supreme Court quashed FIR No. 103 of 2022 and FIR No. 751 of 2021, along with all proceedings arising therefrom, ruling that the continuation of prosecution against the accused appellant would amount to a travesty of justice and a gross abuse of judicial process. The Court allowed the appeal and disposed of all pending applications.

The Court noted that the allegations made in both FIRs were inconsistent and irreconcilable, particularly regarding the number and timing of alleged sexual encounters. In FIR No. 751 of 2021, the complainant only referred to one incident, whereas in FIR No. 103 of 2022, multiple incidents allegedly predating the earlier FIR were mentioned. This discrepancy raised serious doubts about the credibility of the accusations. Furthermore, the complainant’s history of filing similar complaints, including one against a university professor, suggested a pattern of manipulative conduct. The Court observed that such conduct, coupled with the absence of prima facie evidence to substantiate the allegations, negated any basis for prosecuting the appellant.

The Court also examined chat transcripts submitted by the appellant, wherein the complainant—referred to as ‘Muffin’—admitted to being manipulative, using the appellant for personal gain, and seeking relationships for ulterior motives such as acquiring a green card. These chats revealed a clear intent to exploit and discard partners, casting further doubt on the genuineness of her claims. The Court concluded that even if the appellant did withdraw from a marriage proposal, there was no evidence to support that he had sexual relations under a false promise of marriage or that caste-based discrimination was involved. The allegation of caste-based refusal, made only in the second FIR, was found to be a later exaggeration, unsupported in the initial complaint.

ANALYSIS:

The case primarily revolves around the tension between protecting individuals from genuine exploitation and preventing the misuse of legal provisions for personal vendettas. The Supreme Court’s analysis highlighted significant inconsistencies and contradictions in the complainant’s allegations, especially regarding the timeline and number of alleged sexual encounters. The discrepancies between the two FIRs, filed within a short span but containing conflicting details, undermined the reliability of the complainant’s narrative. Additionally, the complainant’s history of lodging similar complaints and evidence of manipulative behavior, as revealed through chat transcripts, indicated that the accusations could have been motivated by vindictiveness rather than legitimate grievance. This pattern of conduct, combined with the absence of credible prima facie evidence, led the Court to question the authenticity of the charges.

Furthermore, the Court’s detailed review of the chats exposed an intent by the complainant to exploit relationships for personal gain, which further eroded the credibility of her claims. The Court emphasized that even if the accused had withdrawn from the marriage proposal, such a retraction did not amount to criminal conduct under the charges levied. Importantly, the allegation of caste-based discrimination in refusing marriage, introduced only in the later FIR, lacked any substantive foundation and was dismissed as an exaggeration. In balancing the interests of justice, the Court concluded that allowing prosecution to continue in this case would constitute a misuse of the judicial process and a grave injustice to the accused, leading to the quashing of both FIRs and all related proceedings.