SUPREME COURT QUASHES FALSE RAPE CASE BASED ON FABRICATED PROMISE OF MARRIAGE:

The Supreme Court recently quashed a chargesheet alleging rape on the pretext of marriage, holding that the criminal proceedings were instituted with mala fide intent and as an afterthought. A Bench comprising Justice Sanjay Karol and Justice Nongmeikapam Kotiswar Singh set aside a Madhya Pradesh High Court order that had earlier refused to quash the proceedings. The Court found that the filing of the FIR was directly linked to an administrative action initiated against the complainant, indicating an ulterior motive behind the allegations.

The case arose from a complaint lodged by a woman employee working as a Computer Operator with a Municipal Corporation. She accused her colleague, an Assistant Revenue Inspector with whom she had shared a friendship for about five years, of sexual assault on the false promise of marriage. Although the complainant was married and had a son, she claimed that she had entered into a physical relationship with her colleague after receiving assurances of marriage. According to her allegations, on 15 March 2023, the accused coerced her into sexual relations on the pretext of marriage, and this continued until April 2023. She further stated that when she enquired about the marriage, the accused refused and even suggested she marry someone else. This, according to her, prompted her to file an FIR under Sections 376 and 376(2)(n) of the Indian Penal Code.

However, before the FIR was filed, the accused had already lodged several complaints against the complainant. He alleged harassment in the form of repeated threats of suicide and abusive behaviour. The accused had made representations both before the municipal authorities and the police. Acting on these complaints, the Municipal Corporation issued a show-cause notice to the complainant on 6 July 2023, warning her that her employment could be terminated if her conduct did not improve. The FIR was filed nearly four months after the alleged incident and significantly, only after the complainant was served with the show-cause notice.

Taking note of this timeline, the Supreme Court held that the delay in lodging the FIR, coupled with the fact that it was filed immediately after administrative action was taken against the complainant, cast serious doubt on the genuineness of the allegations. The Court observed that this sequence of events opened a clear possibility that the FIR was not a bona fide complaint but rather a retaliatory measure aimed at protecting the complainant from the consequences of her workplace misconduct. It described the FIR as being “an afterthought” and “a vehicle for vengeance.”

In arriving at its decision, the Court relied on the principle laid down in State of Haryana v. Bhajan Lal (1992), where it was held that criminal proceedings could be quashed if they were instituted with mala fide intent or for an ulterior motive. The Court also referred to Mohd. Wajid v. State of U.P. (2023), where it was emphasised that in cases of potentially vexatious prosecution, courts must go beyond the contents of the FIR and consider the broader circumstances.

The Bench further reasoned that if the complainant’s allegations were taken at face value, her first course of action should have been to approach the authorities immediately upon realising that the promise of marriage was false. The fact that she delayed her complaint and chose to act only after facing disciplinary proceedings significantly undermined her case. In such circumstances, the Court concluded that the continuation of criminal proceedings would amount to an abuse of process of law.

Accordingly, the Supreme Court quashed both the FIR and the chargesheet, reiterating that the criminal justice system cannot be misused as a tool of personal vengeance or to settle scores arising out of workplace disputes. The ruling reinforces judicial caution against permitting prosecutions that are not based on genuine grievances but are driven by ulterior motives.