BATLANKI KESHAV (KESAVA) KUMAR ANURAG VERSUS STATE OF TELANGANA & ANR., 2025
The Criminal law case on quashing rape and SC/ST Act charges based on false promise of marriage and abuse of legal process.
Judgement Details
Court
Supreme Court of India
Date of Decision
31 May 2025
Judges
Justice Vikram Nath ⦁ Justice Sandeep Mehta
Citation
Acts / Provisions
Facts of the Case
-
The complainant accused the appellant of forcible sexual intercourse under a false promise of marriage.
-
The complainant initially filed an FIR omitting key details, later filed a second FIR alleging repeated incidents of sexual assault and caste-based discrimination under the SC/ST Act.
-
Evidence including chats revealed the complainant’s manipulative and vindictive behaviour, threatening criminal action if refused marriage and admitting to using other men similarly.
-
The appellant retracted from the marriage proposal due to the complainant’s aggressive and obsessive conduct.
Issues
-
Whether sexual intercourse was committed by the accused under a false promise of marriage?
-
Whether the offence under the SC/ST Act was validly invoked or a misuse to harass the accused?
-
Whether the complainant’s conduct indicated manipulation and vindictiveness affecting the credibility of the allegations?
-
Whether the continuation of proceedings amounted to abuse of the legal process?
Judgement
-
The Court found the complainant’s allegations to be unsubstantiated and malicious.
-
The SC/ST Act charges were added later and found to be untenable.
-
The accused was justified in withdrawing from the marriage upon discovering the complainant’s behaviour.
-
The continuation of proceedings was deemed an abuse of process of law.
Held
-
The FIR and criminal proceedings against the accused were quashed.
-
The complainant’s case was dismissed as a fabrication and misuse of the judicial system.
Analysis
-
The Court’s reasoning hinged heavily on digital evidence (chats) showing the complainant’s intent and manipulative patterns.
-
It reaffirmed that false promise of marriage as a ground for rape charge requires genuine intent and absence of coercion, which was missing here.
-
The late introduction of SC/ST offences indicated malicious intent to invoke harsher laws.
-
The judgment emphasizes the importance of credibility and conduct of complainants in sexual offence cases, balancing protection against misuse of laws.
-
It highlights judicial caution to prevent abuse of criminal laws to harass individuals under false allegations.