Allegations in FIR and Material on Prosecution Do Not Constitute Offence: Supreme Court Upheld Quashing of FIR in Relationship Turned Rape Allegation Case

The Supreme Court of India, in a landmark decision on 18^th March 2024, upheld the Karnataka High Court’s order quashing proceedings against the accused in a case of alleged rape, forceful abortion, and caste-based discrimination under IPC and SC/ST Act. The apex court emphasized the absence of sufficient grounds for the continuation of the case, thereby dismissing the criminal appeal filed against the High Court’s order.

Facts and Issues Arising: The appellant, Ms. X, accused Mr. A and others of establishing a sexual relationship under a false promise of marriage, leading to pregnancy and a subsequent abortion. The complaint included severe charges under IPC and SC/ST Act against the partner and his family members. The central issue revolved around the alleged forcible abortion and false promise of marriage.

Court’s Assessment: The court meticulously assessed the case, focusing on the changed narratives and inconsistencies in the appellant’s statements. The appellant initially claimed hospitalization for abortion, later altered to consuming Ayurvedic medicine leading to abortion. The court referenced notable cases like Pramod Suryabhan Pawar v. State of Maharashtra and Shambhu Kharwar v. State of Uttar Pradesh, highlighting criteria for determining consent and false promises of marriage in sexual relationships.

The Supreme Court, applying the Bhajan Lal Guidelines from State of Haryana v. Bhajan Lal, found that the High Court’s decision fit under categories where allegations do not constitute an offence or are absurd or inherently improbable. The apex court noted the importance of not conducting a mini-trial at this stage and the necessity to avoid the abuse of legal processes.

Decision: The Supreme Court dismissed the appeal, upholding the High Court’s decision to quash proceedings against the accused. The Court concluded that there were no sufficient grounds for the case to proceed, thus preventing any miscarriage of justice.

Date of Decision: 18^th March 2024

Ms. X vs. Mr. A and Others