A Bundle of Lies Full of Fabricated and Malicious Allegations: Supreme Court Quashes Rape FIR Based on False Promise of Marriage

Allowing Prosecution Would Be a Travesty of Justice: - Supreme Court of India quashed two FIRs accusing the appellant of rape under a false promise of marriage and caste-based discrimination. The Bench comprising Justices Vikram Nath and Sandeep Mehta held that the complaints were “a gross abuse of the process of Court” and that their continuation would amount to “a travesty of justice.”

The apex court found glaring inconsistencies between the FIRs, a disturbing pattern of vindictive complaints by the complainant, and a complete absence of prima facie material to support the charges under Section 376(2)(n) of IPC and Section 3(2)(v) of the SC/ST (Prevention of Atrocities) Act, 1989. The appeal was allowed, and both FIRs and related proceedings were quashed.

The appellant, a U.S.-based professional, had come into contact with the complainant through a matrimonial site. A mutual agreement to marry allegedly followed. However, the relationship deteriorated when the appellant, citing her aggressive sexual behavior and manipulative tendencies, withdrew from the arrangement.

The first FIR (No. 751/2021) filed on June 29, 2021, alleged a single instance of non-consensual intercourse on June 24, 2021, and accused the appellant of deceit. This FIR resulted in the grant of anticipatory bail and was ultimately closed with no case made out.

However, a second FIR (No. 103/2022), filed months later and based on similar facts, alleged multiple instances of rape and caste-based discrimination. This complaint was registered after the original FIR was forwarded from a different jurisdiction and converted into a more serious set of charges under IPC and the SC/ST Act.

The appellant challenged both FIRs under Section 482 of CrPC, asserting them as vindictive and manipulative.

At the core of the case was the question of whether the FIRs—particularly the second—disclosed any offence or amounted to an abuse of legal process.

The Supreme Court underscored the absence of any credible evidence to sustain allegations of rape under false promise of marriage, observing:

“There is no material—what to say of prima facie material—on record to substantiate the allegations of cheating or sexual intercourse under a false promise of marriage.” [Para 22]

The Court took note of the complainant’s highly educated background, her age (30 years), and the consensual nature of the relationship, stating:

“It is inherently improbable that the complainant would have forgotten or omitted to mention these incidents of sexual intercourse made under a false promise of marriage while filing the earlier FIR.” [Para 23]

The Court further observed that the complainant had previously filed an identical complaint against another man—an Assistant Professor at Osmania University—in 2019, also alleging exploitation under the promise of marriage.

Chats Reveal Manipulative Behaviour and Malicious Intent:

The Court was particularly persuaded by chat transcripts and call recordings that portrayed the complainant, referred to as "Muffin", as manipulative and calculating:

“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.” [Para 25]

These admissions, the Court said, were “a stark reality about the behavioral pattern” of the complainant and indicative of a “vindictive and manipulative tendency.” [Para 26]

The apex court opined that the appellant was justified in backing out from the marriage due to these disturbing behavioural patterns:

“The accused appellant was absolutely justified in panicking and backing out from the proposed marriage.” [Para 27]

On Caste Allegation: Exaggerated and Afterthought:

The FIR filed in 2021 had made no reference to caste-based rejection. The caste angle appeared for the first time in the later FIR filed in 2022. The Court saw this as an exaggerated afterthought: “Apparently this allegation… lodged almost after seven months is nothing but a sheer exaggeration which must be discarded.” [Para 29]

The Bench delivered a strongly worded verdict: “The impugned FIR No. 103 of 2022 is nothing but a bundle of lies full of fabricated and malicious unsubstantiated allegations.” [Para 30]

It concluded that continuation of proceedings would only serve to harass the accused and mock the judicial process: “Allowing prosecution… would be nothing short of a travesty of justice.” [Para 30]

Accordingly, the Court: Quashed FIR No. 103/2022 and FIR No. 751/2021 and Set aside all consequential proceedings.

The Supreme Court’s decision in Batlanki Keshav Kumar Anurag v. State of Telangana & Anr. marks a strong stance against misuse of criminal law in personal relationships, particularly when serious allegations such as rape and caste atrocities are weaponized.

By emphasizing the importance of consistency in complaints, conduct of the complainant, and genuineness of allegations, the judgment reinforces the need for courts to guard against malicious prosecution and uphold the integrity of criminal justice.

“Facts on record clearly establish the vindictive and manipulative tendencies of the complainant… prosecution would be a travesty of justice.” [Para 30]

Date of Decision: May 29, 2025