The Lucknow Bench of the High Court of Judicature at Allahabad has quashed criminal proceedings and a summoning order in a case involving allegations of rape on the false promise of marriage. Hon’ble Justice Brij Raj Singh, while exercising inherent powers under Section 482 of the Cr.P.C., observed that the dispute was a “classic case of a consensual relationship turning acrimonious” and was instituted with an “ulterior motive for wreaking vengeance.”
Background of the Case
The applicants—an MNC engineer and his parents—challenged the proceedings of Complaint Case No. 53786 of 2022. The case originated after the engineer (Applicant No. 3) and the complainant met through a matrimonial website in September 2021. An engagement ceremony was held in October 2021, and marriage dates were finalized for November 2022.
The relationship deteriorated in February 2022 after the applicant received obscene photographs of the complainant from a third party, revealing undisclosed prior relationships. Despite the complainant taking a religious oath to deny current involvement, she eventually blocked the applicant and fixed her marriage with another individual for the exact date previously reserved for the applicant. Subsequently, she initiated criminal proceedings alleging that her consent for physical relations was obtained through a fraudulent promise of marriage.
Arguments of the Parties
Counsel for the applicants, Sri Nadeem Murtaza, contended that the relationship was entirely consensual and that the marriage remained unsolemnized due to the complainant’s own conduct. He argued that the material on record—including the fact that the complainant fixed her marriage elsewhere on the same date—categorically disproved the allegation of a “false promise” at the inception of the relationship.
The learned AGA-I, Sri Rao Narendra Singh, appearing for the State, opposed the quashing prayer. He asserted that the prosecutrix’s statement was sufficient to warrant a trial and that the court should not interfere with the summoning order at this stage.
Judicial Analysis: The Four-Step Veracity Test
The High Court centered its analysis on the “Four-Step Test” delineated in the Supreme Court precedent of Pradeep Kumar Kesharwani Vs. State of Uttar Pradesh (2025). As noted in paragraph 19 of the judgment, the Court evaluated the sustainability of the criminal proceedings based on the following criteria:
- Impeccable Material: Whether the material relied upon by the accused is of “sterling and impeccable quality.”
- Overruling Factual Assertions: Whether such material is sufficient to persuade a reasonable person to dismiss the factual basis of the accusations as false.
- Refutation Capability: Whether the material is such that it cannot be justifiably refuted by the complainant or the prosecution.
- Abuse of Process: Whether continuing the trial would constitute an abuse of the court’s process.
Applying these steps, the Court found that the applicant had remained willing to marry the complainant until the discovery of “unfortunate developments” regarding her conduct. The Court observed that the essential ingredients of Section 376 IPC were absent, as there was no evidence that the promise to marry was “false” or “made in bad faith” at the time it was given.
The Decision
The High Court concluded that the proceedings were maliciously instituted to settle a personal grudge following a failed engagement. Citing State of Haryana Vs. Bhajan Lal (1992), Justice Brij Raj Singh held that permitting the prosecution to continue would result in an abuse of the process of law.
The Court emphasized:
“Legal acts and laws are fundamentally designed to dispense justice, maintain social order and protect rights, rather than serve as tools for personal vengeance, retaliation or settling private scores.”
The Court allowed the application, quashing the entire proceedings of Complaint Case No. 53786 of 2022 and the summoning order dated 19.11.2022 passed by the Additional Chief Judicial Magistrate-IV, Lucknow.
Case Details:
- Case Title: Fatima Begum and 2 others Versus The State of U.P. and another
- Case Number: APPLICATION U/S 482 No. 9282 of 2022
- Bench: Justice Brij Raj Singh
- Date: April 7, 2026
