In Batlanki Keshav (Kesava) Kumar Anurag Versus State Of Telangana & Anr, the Supreme Court quashed a rape case against a man accused of forcing sexual relations under false pretences of marriage promise on Thursday, May 29. The court noted that the complainant’s previous actions were dubious, as she acted in a manipulative and vindictive manner, threatening to take criminal action against the accused and others if they did not marry her.
The bench, consisting of Justice Vikram Nath and Justice Sandeep Mehta, examined the case in which the complainant, Respondent no. 2, a well-educated adult, initially omitted significant details in the first FIR and subsequently submitted a second FIR alleging several instances of forcible sexual intercourse and caste-based refusal to marry. The violations under the SC/ST Act were also included in the FIR.
According to the Court’s review of her chats, the complainant had an unfortunate tendency of making false accusations against other men as well. She would annoy her victims to the point where they would leave her, and she would be happy to start the next one. Additionally, she claimed to be utilising the accused-appellant. She was “trying to get a green-card holder” and “investing on the next victim,” according to some of her conversations.
The court said, “These chats depict the stark reality about the behavioral pattern of the de-facto complainant who appears to be having manipulative and vindictive tendency.”, the court said. “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.”,.
Furthermore, Justice Nath’s judgement said that the complainant’s claim of a caste-based violation under the SC/ST Act was unsupportable since it was made later just to coerce the appellant into invoking more severe penalties. As per Court’s observation, “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 with the de-facto complainant on the ground that she belonged to the Scheduled Castes/Scheduled Tribes community.”.
Finally, the Court determined that the continuation of the crime against the Appellant was an abuse of process of law, therefore the appeal was granted, and the existing criminal proceedings were quashed. The court stated, “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.”