Source: Supreme Court  

Why in News? 

Recently, the bench of Justice Vikram Nath and Justice Sandeep Mehta quashed the rape case, citing the complainant's manipulative conduct and abuse of legal process. 

•  The Supreme Court held this in the matter of Batlanki Keshav (Kesava) Kumar Anurag v. State of Telangana & Anr, (2025). 

What was the Background of Batlanki Keshav (Kesava) Kumar Anurag v. State of Telangana & Anr,2025 Case? 

• The complainant and the accused appellant met through the 'Bharath Matrimony' website while the appellant was residing in the United States of America, and they agreed to marry each other with an initial wedding date fixed for January 6, 2021. 
• The appellant avoided the scheduled marriage date and returned to the United States without marrying the complainant but later came back to India and allegedly established physical relations with her. 
• Following a previous complaint filed by the complainant, both parties reached a resolution at the police station in the presence of the Inspector, whereby the appellant agreed to marry the complainant and get the marriage registered, with a written agreement signed by both parties. 
• The appellant and his mother subsequently showed reluctance towards the marriage on various pretexts, making excuses about auspicious dates and ceasing communication about wedding arrangements while allegedly harassing the complainant. 
• The complainant filed the first FIR (Crime No. 751 of 2021) on June 29, 2021, alleging cheating and breach of promise to marry, mentioning only one incident of sexual intercourse dated 24th June, 2021. 
• Subsequently, the complainant filed another complaint in Kerala which was transferred to Cyberabad, resulting in FIR No. 103 of 2022 being registered on 1st February, 2022. 
• The second FIR alleged multiple incidents of forcible sexual intercourse on May 4, May 11, May 28, and June 7, 2021, along with accusations that the appellant refused to marry her citing caste differences. 
• The charges included offences under Section 376(2)(n) of the Indian Penal Code for rape and Section 3(2)(v) of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989. 
• The appellant sought quashing of the second FIR through a petition under Section 482 of the Criminal Procedure Code, which was initially rejected by the Telangana High Court. 
• Investigation revealed that the complainant had previously filed similar complaints against other men, including an Assistant Professor at Osmania University in 2019, with identical allegations of cheating and sexual exploitation under false promise of marriage. 

What were the Court’s Observations? 

• The Court noted significant contradictions between the two FIRs filed by the complainant, particularly that the first FIR mentioned only one incident of sexual intercourse while the second FIR alleged multiple incidents that predated the first complaint, making it improbable that an educated 30-year-old woman would omit such crucial details. 
• Upon examining chat records between the parties, the Court observed that the complainant had admitted to being manipulative and stated she was "trying to get a green card holder," while also mentioning her intention to "invest on the next victim" and irritate her targets until they abandoned her. 
• The Court found that the complainant exhibited a pattern of vindictive and manipulative behavior, having previously filed similar complaints against other men, which established her tendency to lodge false allegations when relationships did not proceed as desired. 
• The Court determined that the appellant was justified in withdrawing from the proposed marriage upon discovering the complainant's aggressive sexual behavior and obsessive nature, as evidenced by the chat records and her documented psychological condition. 
• Regarding the caste-based allegations under the SC/ST Act, the Court observed that these were introduced only in the second FIR filed seven months later, with no mention of caste discrimination in the original complaint, indicating fabrication to invoke harsher penal provisions. 
• The Court concluded that continuing the prosecution would constitute a travesty of justice and gross abuse of the judicial process, as the second FIR contained fabricated and malicious allegations without substantive evidence. 
• Ultimately, the Court held that the impugned FIR was nothing but a bundle of lies designed to harass the appellant, and quashed both FIRs along with all consequent proceedings to prevent further abuse of the legal system. 

What is Promise to Marry under Bharatiya Nyaya Sanhita, 2023 (BNS) ? 

• Section 69 of BNS, 2023 specifically criminalises sexual intercourse obtained through deceitful means or false promise of marriage, carrying punishment of imprisonment up to ten years and fine. 
• Courts must establish that the accused had no intention of marrying from the beginning, the false promise was the primary reason for consent, and the accused knew consent was based on this deceptive promise  
• The provision distinguishes between genuine promises that remain unfulfilled due to circumstances versus deliberately false promises made with malicious intent from inception. 
• This legal framework evolved from judicial recognition of 'rape on false promise of marriage' in landmark cases like Anurag Soni v State of Chhattisgarh,2019 Rape on False Promise of Marriage by the Supreme Court of India. 
  • Anurag Soni v State of Chhattisgarh - Established judicial recognition of rape on false promise of marriage as distinct sexual offence category. 
• Supreme Court has expressed concerns about increasing criminal complaints in long-term relationships, noting it would be implausible for complainants to continue relationships for years under mere promises without evidence of initial deception For Offence of Rape on False Promise to Marry, Physical Relationships Must Be Shown to Be Only Based on Marriage Promise. 
• Recent Supreme Court judgment held that false promise allegations become baseless when relationships actually culminate in solemnization of marriage  
• Courts exercise judicial restraint to prevent misuse, particularly in cases involving vindictive complainants or natural relationship deterioration.