Introduction
This case deals with the quashing of a rape FIR where the complainant alleged that the accused had sexual intercourse with her on the false promise of marriage and later retracted due to her caste. The Supreme Court quashed the FIR citing the manipulative and vindictive nature of the complainant, as reflected in her chats and behavior. The Court held that continuing the criminal proceedings would be an abuse of the process of law.
- Section 375 IPC (Now Sec 63 of BNS,2023) – Rape.
- Section 376 IPC (Now Sec 64 of BNS,2023) – Punishment for rape.
- Section 3(1)(w)(ii) of the SC/ST (Prevention of Atrocities) Act, 1989 – Sexual exploitation of SC/ST woman.
- Section 482 CrPC (Now Sec 528 of BNSS,2023) – Inherent powers of the High Court to quash criminal proceedings.
- Article 136 of the Constitution – Special Leave Petition jurisdiction of the Supreme Court.
Facts of the Case
The complainant, a well-educated major woman, entered into a relationship with the accused. She initially filed FIR with limited allegations, but subsequently filed a second FIR, adding more serious charges including multiple incidents of forcible sexual intercourse and offences under the SC/ST (Prevention of Atrocities) Act. The accused moved the Supreme Court seeking quashing of the FIR under Article 136 read with Section 482 CrPC, claiming the allegations were fabricated. The chats between the complainant and others were produced, showing her tendencies to manipulate men and threaten legal action for marriage. She also referred to her plans to target a "green-card holder" and to "invest on the next victim."
You can also read the Judgement of Shah Bano Case
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Issues
- Whether the FIR registered against the appellant disclosed a prima facie offence of rape based on a false promise of marriage?
- Whether the subsequent inclusion of offences under the SC/ST Act was legitimate?
- Whether continuation of the criminal proceedings amounted to abuse of process of law?
Contentions of the Petitioner
The complainant concealed facts and filed multiple FIRs with changing and exaggerated allegations. The chats revealed the complainant's vindictive nature and intention to manipulate men into marriage. The relationship was consensual, and the accused backed out of marriage due to her obsessive and aggressive sexual behavior. The SC/ST allegations were an afterthought, added only to harass the appellant. The FIR is a misuse of criminal law for vengeance and should be quashed.
Contentions of the Respondent
The accused had sexual intercourse on the promise of marriage and later backed out due to her caste. Allegations of rape and caste-based refusal were serious and warranted investigation. The chats were taken out of context and do not discredit the criminality of the accused’s conduct. The complaint disclosed cognizable offences and should not be quashed at this preliminary stage.
Court’s Analysis
The Court examined the complainant’s chats, noting she displayed a manipulative and vindictive pattern, including:
- Using men and dumping them.
- Targeting green-card holders.
- Investing in new victims.
The Court found her to be aggressive and obsessive, justifying the accused’s decision to back out of marriage. Her own conduct, especially threats of false complaints, undermined her credibility. The SC/ST Act charge was found to be an afterthought introduced only to invoke harsher provisions. The FIR was described as a bundle of lies, fabricated and malicious, intended to harass the appellant. The Court held that merely backing out of marriage does not constitute rape, especially when consent was not obtained through deception.
Conclusion
The Supreme Court held that continuation of proceedings would be an abuse of process. The FIR and the criminal case were quashed. The Court emphasized that criminal law should not be used as a tool for personal vendetta.
