Supreme Court Quashes Rape Case Over False Marriage Promise; Flags Complainant’s 'Manipulative & Vindictive' Behaviour

The Bench of Justice Vikram Nath and Justice Sandeep Mehta allowed the appeal filed by the accused and set aside the criminal proceedings initiated against him, including FIR No. 103 of 2022.

The Court found that the allegations were riddled with inconsistencies and malicious intent, and were filed with the objective of harassing the accused.

The case arose after the complainant, a well-educated and major woman, initially lodged an FIR alleging certain incidents without disclosing key facts. Subsequently, she filed a second FIR in which she accused the appellant of multiple incidents of forcible sexual intercourse and alleged that the accused had refused to marry her due to her caste identity, leading to the addition of offences under the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act.

However, on examining the material on record, including WhatsApp chats and other communications, the Court found that the complainant had a pattern of threatening criminal proceedings against men who refused to marry her.

In some of her chats, she admitted to "irritating" her partners to the point that they would leave her, allowing her to “move on to the next one.” She also spoke about targeting individuals for personal gain, including “trying to get a green-card holder” and needing to “invest on the next victim.”

“These chats depict the stark reality about the behavioural pattern of the de-facto complainant who appears to be having manipulative and vindictive tendency,” the Court observed.

The Bench noted that the accused was justified in withdrawing from the proposed marriage upon discovering the aggressive and obsessive nature of the complainant.

“Thus, in our opinion, the accused appellant was absolutely justified in panicking and backing out from the proposed marriage upon coming to know of the aggressive sexual behaviour and the obsessive nature of the de-facto complainant,” the Court stated.

Significantly, the Court took strong exception to the belated invocation of the SC/ST Act in the second FIR. Justice Nath, authoring the judgment, held that the caste-based allegations were clearly an afterthought, introduced merely to invoke more stringent provisions and pressurise the accused.

“Hence, even assuming that the accused appellant retracted from his promise to marry the complainant, it cannot be said that he indulged in sexual intercourse with the de-facto complainant under a false promise of marriage or that the offence was committed by him on the ground that she belonged to the Scheduled Castes/Scheduled Tribes community,” the Bench stated.

The Court found that the continuation of the criminal proceedings against the appellant would amount to an abuse of process of law. It noted that the allegations in the FIR were fabricated, malicious, and devoid of substance.

“The impugned FIR No. 103 of 2022 is nothing but a bundle of lies full of fabricated and malicious unsubstantiated allegations levelled by the complainant. The facts on record clearly establish the vindictive and manipulative tendencies of the complainant and these aspects have a great bearing on the controversy,” the Court concluded.

Accordingly, the appeal was allowed, and all pending criminal proceedings arising out of the FIR were quashed.