Section 482 CrPC | FIR Based On Consensual Relationship Gone Sour Cannot Be Sustained To Coerce Marriage: Supreme Court

"The complaint was filed specifically to coerce the appellant into marrying the complainant, failing which she wanted punitive action taken for the sexual assault and the exploitation." Supreme Court, in a significant ruling dated October 1, 2026, held that criminal proceedings initiated to coerce a partner into marriage following a soured consensual relationship constitute an abuse of the process of the court.

 A bench of Justices J.B. Pardiwala and K. Vinod Chandran observed that when allegations of sexual assault are delayed by years and the underlying motive is to force matrimony, the court must exercise its inherent powers under Section 482 of the CrPC to prevent the wastage of judicial time.

The appellant, Sachin Gupta, approached the Supreme Court challenging an order of the High Court that refused to quash an FIR registered against him for alleged rape and assault. The complainant, a bank employee, had alleged that the appellant committed rape in May 2024 and subsequently promised to marry her to avoid a police complaint. The FIR further alleged that the appellant later assaulted the complainant in a hotel and threatened her. The appellant contended that the FIR was a "counter-blast" to his own complaints regarding the complainant's attempt to extort money from him.

The primary questions before the court were whether the material provided by the accused was sufficient to establish that the allegations were false and whether allowing the trial to proceed would amount to an abuse of the judicial process. The court further examined whether the FIR met the criteria for quashing set out in the precedent of Pradeep Kumar Kesarwani v. State of Uttar Pradesh.

Applying The Four-Step Test For Quashing

The Court reiterated the necessity of the four-step test established in Pradeep Kumar Kesarwani, which mandates that the material relied upon by the accused must be of "sterling and impeccable quality" to justify quashing. The bench noted that the appellant had produced evidence of prior complaints lodged against the respondent, which indicated that the relationship had soured due to disputes over financial investments and alleged extortion.

Court Finds Relationship Consensual

The bench observed that the timeline of the allegations was inherently suspicious, noting that the claim of rape was delayed by over one and a half years. The court further pointed out that the complainant’s allegations of being impregnated and undergoing abortions twice were unsupported by any medical record, rendering the factual basis of the accusations weak and unreliable.

No Case Made Out For Prosecution

The Court held that the ingredients of the offences alleged against the appellant and his co-accused were not made out. The bench remarked that the criminal machinery was being improperly used to resolve a private civil dispute and to pressure the appellant into marriage. Consequently, the Court found that the continuation of the trial would not serve the ends of justice.

"The allegation of rape, hence, is delayed by more than one and a half years."

The Supreme Court set aside the High Court's order and quashed the charge sheet pending before the Chief Judicial Magistrate, Ambikapur. The court directed that no criminal proceedings should continue against the appellant or the other accused, concluding that the entire dispute stemmed from a consensual relationship that had since deteriorated.

Date of Decision: 01 October 2026