Justice Must Serve, Not Harass: Supreme Court Quashes Rape Case Amid Amicable Settlement, Citing Abuse of Process

“Continuing Trial Will Only Disturb Her Peace”: In a significant ruling Supreme Court of India exercised its inherent powers under Section 482 of the Code of Criminal Procedure to quash criminal proceedings, including serious charges under Section 376 IPC, citing “peculiar facts and circumstances” and the unequivocal stand of the complainant not to pursue prosecution. The Bench comprising Justice Vikram Nath and Justice Sanjay Kumar highlighted that while courts are cautious in quashing serious offences, justice must not be reduced to a mere mechanical application of law when continuation of prosecution serves no meaningful purpose.

Opening with a sharp criticism of mechanical prosecution, Justice Vikram Nath observed, “We are confronted with an unusual situation where the FIR invoking serious charges, including Section 376 IPC, was filed immediately following an earlier FIR lodged by the opposing side. This sequence of events lends a certain context to the allegations and suggests that the second FIR may have been a reactionary step.”

The case involved two FIRs filed within a span of 24 hours at Mehunbare Police Station, Jalgaon District. The first FIR (No. 302/2023), registered on 20.11.2023, accused the appellants of assault and criminal intimidation under Sections 324, 141, 143, 147, 149, 452, 323, 504, and 506 of the IPC. The second FIR (No. 304/2023), lodged on 21.11.2023, added grave allegations including rape under Section 376, along with charges under Sections 354-A, 354-D, 509, and 506 IPC, targeting Prabhakar, father of one of the appellants.

The Supreme Court underlined the unusual sequence, noting, “The timing of the second FIR, coming immediately after the first FIR, raises legitimate questions about retaliatory motives.”

Significantly, the complainant in the second FIR filed a sworn affidavit before the High Court, expressing no intention to continue prosecution. She stated that the matter had been settled amicably, she had received ₹5,00,000 towards marriage-related expenses, and more crucially, that continued prosecution would “disrupt her settled married life.” The High Court, however, refused to quash the case, citing the non-compoundable nature of Section 376 IPC.

Setting aside the High Court’s decision, the Supreme Court pointed to the broader jurisprudential principle that powers under Section 482 CrPC are designed to prevent injustice and abuse of legal processes. “Though ordinarily Section 376 IPC cases are not quashed on settlement, the facts justified exercise of inherent powers to prevent abuse of process,” the Court noted.

Referring to the consistent and voluntary position of the complainant, the Bench observed, “Her stand is neither tentative nor ambiguous, she has consistently maintained, including through an affidavit on record, that she does not support the prosecution and wants the matter to end.”

The Court noted the futility of continuing criminal proceedings where the prime witness, i.e., the complainant, has firmly withdrawn from participation, stating, “Continuation of the trial would not serve any meaningful purpose. It would only prolong distress for all concerned, especially the complainant, and burden the Courts without the likelihood of a productive outcome.”

The Supreme Court accordingly quashed both FIR No. 302 of 2023 and FIR No. 304 of 2023, along with Sessions Case No. 29 of 2024, observing, “The continuation of the criminal proceedings would serve no useful purpose and would only amount to abuse of process.”

The ruling underscores the Court’s commitment to nuanced justice delivery, affirming that rigid application of law must give way to contextual fairness. The Bench closed by reiterating, “The power of the Court under Section 482 CrPC to secure the ends of justice is not constrained by a rigid formula and must be exercised with reference to the facts of each case.”

Date of Decision: 14 July 2025