Quashing “Rape-on-False-Promise-to-Marry” FIRs: Supreme Court’s New Corrective for Inconsistent Allegations & Abuse of Process

Introduction

In Batlanki Keshav (Kesava) Kumar Anurag v. State of Telangana & Anr., 2025 INSC 790, the Supreme Court of India dealt with a criminal appeal arising from the refusal of the Telangana High Court to quash an FIR alleging repeated rape (Section 376(2)(n) IPC) and caste-based atrocity (Section 3(2)(v) SC/ST (POA) Act). The appellant, a U.S.-based professional, contended that the complainant, an educated woman, had fabricated the accusations after an acrimonious breakdown of their proposed marriage.

The apex court seized the matter under its criminal appellate jurisdiction and, after examining transcripts, photographs, and procedural history, set aside both the impugned FIR (Crime No. 103/2022) and an earlier FIR (Crime No. 751/2021), thereby creating an important precedent on:

• When Section 482 CrPC should be invoked to quash prosecutions alleging “rape on false promise to marry”.
• The permissibility of relying on digital evidence and prior conduct to test bona fides at the quashing stage.
• Guarding against misuse of the SC/ST Act as an afterthought.

Summary of the Judgment

Detailed Analysis

A. Precedents Cited & Their Influence

Although the judgment is short on explicit citations, it implicitly relies on and extends the logic of several landmark rulings:

1. Pramod Suryabhan Pawar v. State of Maharashtra (2019) 9 SCC 608
   The Court reiterated that to attract Section 376 on a promise-to-marry theory, the promise must be a “false promise” given from the very inception. Subsequent unwillingness, howsoever abrupt, does not ipso facto convert consensual sex into rape.
2. Maheshwar Tigga v. State of Jharkhand (2020) 10 SCC 108
   This case underscored the need to examine whether the victim, as a reasonable adult, could perceive the genuineness of the promise. The present judgment uses the complainant’s education and age to apply that test.
3. State of Haryana v. Bhajan Lal 1992 Supp (1) SCC 335
   Grounds (1) and (7) of Bhajan Lal (manifest falsity and abuse of process) were invoked to justify quashing under Section 482 CrPC.
4. Kailash Chandra Agrawal v. State of Uttar Pradesh (2014) 16 SCC 551
   Allowed courts to look into defence documents (e.g., chats, photographs) at the quashing stage if they are undisputed. The present Bench candidly evaluates such material.

B. The Court’s Legal Reasoning

1. Inherent Contradictions
   Four alleged incidents (4 May–7 Jun 2021) were never mentioned in the earlier FIR (29 Jun 2021) lodged barely weeks later. Such unexplained omission suggested fabrication.
2. Pattern of Vexatious Complaints
   A 2019 complaint against a university professor with nearly identical accusations supported the defence theory of the complainant’s habitual litigation.
3. Digital Evidence
   Chat transcripts revealed admissions of manipulation (“invest on the next victim”, “get a green card holder”), casting serious doubt on the complainant’s credibility. These texts were uncontroverted in the State’s counter-affidavit.
4. Absence of Caste Motive
   The caste allegation surfaced only seven months after the earlier FIR and hence was deemed a “sheer exaggeration”. No evidence even prima facie linked the alleged sexual conduct with caste prejudice.
5. Educated Adult Complainant
   The Court factored in the complainant’s age (30) and education to infer an ability to give informed consent.
6. Test for Section 482 Intervention
   Using Bhajan Lal categories, the Bench held that continuation of proceedings would (i) manifestly abuse the judicial process and (ii) amount to harassment, thus warranting quashment at the threshold.

C. Impact on Future Jurisprudence

• Elevated Threshold for “False Promise” Rape Cases
  Courts may now scrutinise consistency across multiple FIRs and look at digital/social-media trail before allowing prosecutions to proceed.
• Checks on SC/ST Act Over-Invocation
  Mere caste difference—if introduced belatedly—will not sustain Section 3(2)(v) charges unless the offence is on the ground that the victim belongs to an SC/ST, a phrase re-emphasised here.
• Encouragement for Defence to Produce Verifiable Digital Evidence Early
  The decision legitimises the filing of chats, e-mails and photos at the Section 482 stage where authenticity is uncontested.
• Protection Against Weaponisation of Criminal Law
  The judgment reinforces that criminal process should not become a tool for settling personal scores, especially in failed matrimonial negotiations.

Complex Concepts Simplified

• Section 376(2)(n) IPC – Punishes repeated (habitual) rape. Here, every alleged act of intercourse was said to constitute a distinct offence, aggregated under this provision.
• Section 3(2)(v) SC/ST (POA) Act – Enhances punishment if any offence is committed “on the ground that” the victim belongs to an SC/ST community. Proof of caste-based motive is indispensable.
• Section 482 CrPC – Empowers High Courts to quash criminal proceedings to prevent abuse of process or secure the ends of justice.
• Closure Report – A final report under Section 173(2) CrPC concluding that no offence is made out. Acceptance by the court terminates the case unless a protest petition is filed.
• Charge-sheet – Police report alleging that evidence exists to prosecute the accused. Its filing does not foreclose quashing where the material is demonstrably unreliable or mala fide.

Conclusion

Batlanki Keshav brings a necessary balance to an area rife with factual grey zones—sexual relationships that sour before marriage. By stressing internal consistency, contemporaneous conduct, and digital footprints, the Supreme Court has furnished trial and appellate courts with a sharper lens for filtering out motivated prosecutions.

The ruling does not dilute protections for genuine victims; rather, it underscores that criminal law’s coercive machinery must not be misused as an instrument of revenge. Future litigants and law-enforcement agencies will now have to demonstrate a cogent, contemporaneous, and caste-linked narrative to cross the prima facie threshold in similar cases.

The decision therefore stands as a significant checkpoint against the abuse of rape-and-atrocity provisions while preserving the sanctity of consent and the rigor of due process.