Rape-on-Promise Case: Supreme Court Grants Anticipatory Bail to NRI, Stays LOC and Blue Corner Notice
Supreme Court granted anticipatory bail to a London-based NRI accused in a rape-on-promise case and stayed the Look Out Circular and Blue Corner Notice
The Supreme Court has granted anticipatory bail to a London-based NRI accused of rape on the false promise of marriage, setting aside a Bombay High Court order that had denied him pre-arrest protection.
The complaint was filed by an Advocate who had earlier represented the appellant in his divorce proceedings.
The Bench of Justices B.V. Nagarathna and Ujjal Bhuyan allowed the appeal and quashed the High Court’s order dated October 15, 2025, passed in an anticipatory bail application arising out of FIR No. 56 of 2025 registered at Lonavala City Police Station, Pune Rural.
The FIR invoked offences under Sections 69, 318(4), 3(5) and 316(2) of the Bharatiya Nyaya Sanhita, 2023, along with Section 66E of the Information Technology Act, 2000.
Granting relief, the Court directed that in the event of arrest, the appellant be released on bail on furnishing cash security of Rs. 25,000 with two sureties of the like amount. The Bench also made it clear that the appellant must fully cooperate with the investigation, must not misuse his liberty, and must not influence witnesses or tamper with evidence.
The appellant, an information technology professional residing in London, had earlier approached the Bombay High Court apprehending arrest, but his plea was rejected. He then moved the Supreme Court, which had granted him interim protection on November 17, 2025, directing that no coercive steps be taken.
Before the Supreme Court, the appellant contended that the allegations were false and frivolous, arising out of a consensual relationship that had since ended. It was argued that neither party intended to marry and that the criminal proceedings were an abuse of process.
Senior Advocate Rishi Malhotra appeared for the appellant.
The State opposed the plea, pointing out that coercive measures including a Look Out Circular, Blue Corner Notice, non-bailable warrant and proclamation proceedings had already been initiated against the appellant. The complainant, represented by counsel, supported the State and submitted that the allegations were serious and warranted denial of anticipatory bail.
Allowing the appeal, the Supreme Court also ordered that the Look Out Circular dated March 24, 2025, the Blue Corner Notice, and the order declaring the appellant a proclaimed offender be kept in abeyance.
Taking note of the appellant’s overseas residence, the Bench clarified that if he returned to India for investigation or any other purpose, the present order would protect him in respect of the offences alleged in the FIR. Authorities were directed to inform him of investigation dates well in advance to enable his travel.
AOR Shishir Pinaki and AOR Aaditya Aniruddha Pande appeared for the respondents.
With these directions, the Court allowed both the appeal and the connected interlocutory application.
Case Title: Praveen Manik Kadam v. State of Maharashtra & Anr.
Bench: Justices B.V. Nagarathna and Ujjal Bhuyan
Order Date: January 7, 2026