[2025] 7 S.C.R. 242
(Criminal Appeal No. 2879 of 2025), delivered on 29 May 20251.
Core Issue
The Supreme Court examined the correctness of the High Court’s order that refused to quash a First Information Report (FIR) against the appellant, which alleged sexual relations under a false promise of marriage and also invoked provisions of the Scheduled Castes and the Scheduled Tribes (Prevention of Atrocities) Act, 1989.
Factual Background
The de-facto complainant (Respondent No.2), a highly educated woman aged 30, lodged a complaint against the appellant, alleging that they had a written agreement to marry3…. She claimed that the appellant and his mother later showed reluctance to the marriage and that the appellant compelled her to engage in sexual intercourse4. After the appellant blocked her calls and messages, she filed an FIR (Crime No. 751 of 2021) on 29 June 2021, for offences under Sections 417 (cheating) and 420 (dishonest inducement) of the Indian Penal Code (IPC)67.
Subsequently, she filed another complaint in Kerala, which was forwarded to Madhapur Police Station and registered as a second FIR (Crime No. 103 of 2022) on 1 February 202278. This second FIR alleged that the appellant established sexual relations with her against her wishes on multiple occasions (specifically 4, 11, 28 May 2021, and 7 June 2021) and later refused to marry her, allegedly because she belonged to a “lower caste”7….
High Court’s Decision
The appellant sought to quash the second FIR (Crime No. 103 of 2022) before the High Court, which dismissed his petition. The High Court directed the investigating officer to conclude the investigation without taking coercive steps against the appellant, noting that the parties had not lived together after the first complaint11.
Supreme Court’s Reasoning
The Supreme Court allowed the appeal, quashing both FIRs, based on several key observations:
• Contradictions in FIRs: The Court found “great variance” and “inherent contradictions” between the allegations in the first and second FIRs12. The second FIR detailed multiple instances of sexual intercourse occurring before the first FIR, yet these were not mentioned in the initial complaint9. It was deemed inherently improbable that a 30-year-old educated woman would forget or omit such serious incidents when filing the first FIR3….
• Complainant’s Conduct and Motive: The Court noted that the complainant had previously filed a similar FIR against an Assistant Professor at the university where she studied, alleging identical accusations of cheating and sexual exploitation under a false promise of marriage13…. Translated transcripts of call recordings and chats revealed the complainant’s “manipulative and vindictive tendency,” where she admitted to being manipulative, trying to “get a green card holder,” and needing to “invest on the next victim”13…. She also stated she would “irritate her victims to the extent that they dump her” and that she was using the accused15.
• Lack of Prima Facie Material: The Court concluded that there was no prima facie material to substantiate the allegations of cheating or sexual intercourse under a false promise of marriage312. It held that the appellant was justified in backing out from the proposed marriage upon discovering the complainant’s “aggressive sexual behaviour and the obsessive nature”13….
• Caste Allegation as Exaggeration: The allegation in the second FIR that the appellant dumped her due to her belonging to a Scheduled Caste/Scheduled Tribe community was considered a “sheer exaggeration” because it was not mentioned in the first FIR, lodged almost seven months earlier1013.
Final Outcome
The Supreme Court held that allowing the prosecution to continue would be a “travesty of justice” and a “gross abuse of the process of Court”, as the impugned FIR was a “bundle of lies full of fabricated and malicious unsubstantiated allegations”1013. Consequently, the Court quashed both FIRs (Crime No. 103 of 2022 and Crime No. 751 of 2021) and all associated proceedings in their entirety1319.
