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Batlanki Keshav (Kesava) Kumar Anurag v. The State of Telangana

Criminal Appeal · 2025 INSC 790Decided 29 May 2025
Crl.A. No.-002879-002879 - 2025 (arising out of SLP(Crl.) No(s). 3316 of 2023)
Justice Vikram Nath · Justice Sandeep Mehta

Background

After an earlier FIR and a settlement agreement in which the appellant agreed to marry the complainant, the relationship broke down and the complainant filed a second, more serious FIR alleging that the appellant had forced her into sexual relations on multiple occasions under a false promise of marriage, and had later refused to marry her citing caste. The Telangana High Court declined to quash this second FIR. The appellant contended the allegations were fabricated, exaggerated, and inconsistent with the earlier FIR, and placed on record chat messages and other material suggesting the complainant had a pattern of similar prior complaints.

Decision Breakdown

The Supreme Court found the two FIRs to be materially inconsistent: the later FIR described four to five incidents that had allegedly occurred before the earlier FIR was filed but were never mentioned in it, which the Court found "inherently improbable" for a genuine complainant to omit. It also noted evidence, including the complainant's own messages, suggesting a pattern of manipulative conduct and an earlier, similarly-worded complaint against a different man. Concluding there was no material to substantiate cheating, coerced sexual relations, or a caste-based motive, the Court held continuation of the prosecution would be a gross abuse of the process of law and quashed both FIRs.

Lesson Learnt

The extraordinary power to quash a criminal case at the outset exists precisely for situations where the complainant's own inconsistent statements and prior conduct show the allegations to be fabricated. Courts will not allow prosecution to continue as a tool for harassment once such abuse of process is evident.

Official source (sci.gov.in)View Judgment (PDF)

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