The Supreme Court of India has held that criminal proceedings arising out of a consensual relationship that went sour cannot be sustained when an FIR is lodged primarily to coerce marriage. Setting aside an order of the High Court that declined to quash the criminal case, a bench comprising Justice J. B. Pardiwala and Justice K. Vinod Chandran invoked powers under Section 482 of the Code of Criminal Procedure, 1973 (Cr.P.C.) to quash the chargesheet and proceedings against an appellant and co-accused, concluding that continuing the trial would constitute an abuse of the judicial process.
Background of the Case
The appellant, Sachin Gupta, approached the Supreme Court after the High Court refused to quash FIR No. 326 of 2025, registered on December 5, 2025, at Manipur Police Station in Surguja, Chhattisgarh.
The criminal complaint had been registered on the basis of a first information statement lodged by the second respondent, a woman employed at a bank where the appellant was a frequent customer. In her statement, she alleged that on May 5, 2024, the appellant took her in a car, intoxicated her, and committed rape. She stated that when she regained consciousness, the appellant implored her not to report the matter and agreed to marry her. According to her, the relationship continued thereafter, during which she claimed to have become pregnant twice—in October 2024 and February 2025—and that both pregnancies were aborted.
The complainant further alleged that on October 29, 2025, she was assaulted in a hotel room by the appellant and his cousin, forced out in front of hotel staff, and threatened that intimate videos of their relationship would be made viral. She claimed that when she attempted to lodge a police complaint the following day, the appellant and other accused threatened her life, and that the appellant’s father continued to level threats against her. She explicitly stated in her complaint that she sought to marry the appellant, and if he refused, she desired punitive action against him for sexual exploitation and assault.
Conversely, the appellant submitted that he became acquainted with the second respondent during his visits to the bank. He stated that she obtained his phone number and persistently pestered him to invest in bank schemes. When he refused, she raised allegations against him and extorted money. The appellant initially paid the demanded amounts but later refused to comply further. Consequently, he registered two police complaints—one dated November 7, 2025 (Annexure P1) and another dated December 2, 2025 (Annexure P2). The appellant contended that the subsequent FIR registered by the second respondent on December 5, 2025, was merely a retaliatory counter-blast to the inquiries initiated by the police on his complaints.
Submissions of the Parties
During the hearing, Senior Counsel K. Parameshwar appeared on behalf of the appellant, while Advocate-on-Record Siddhartha Sinha represented the State of Chhattisgarh. Despite notice having been issued to the second respondent (the complainant), no appearance was entered on her behalf.
The Court’s Analysis and Precedent
In assessing whether the criminal proceedings warranted quashing under Section 482 of the Cr.P.C., the Supreme Court referred to the four-step framework established in Pradeep Kumar Kesarwani v. State of Uttar Pradesh and Anr. (which relied on Rajiv Thapar & Ors. v. Madan Lal Kapoor):
“20. The following steps should ordinarily determine the veracity of a prayer for quashing, raised by an accused by invoking the power vested in the High Court under Section 482 of the Cr.P.C.:-
(i) Step one, whether the material relied upon by the accused is sound, reasonable, and indubitable, i.e., the materials is of sterling and impeccable quality?
(ii) Step two, whether the material relied upon by the accused, would rule out the assertions contained in the charges levelled against the accused, i.e., the material is sufficient to reject and overrule the factual assertions contained in the complaint, i.e., the material is such, as would persuade a reasonable person to dismiss and condemn the factual basis of the accusations as false.
(iii) Step three, whether the material relied upon by the accused, has not been refuted by the prosecution/complainant; and/or the material is such, that it cannot be justifiably refuted by the prosecution/complainant?
(iv) Step four, whether proceeding with the trial would result in an abuse of process of the court, and would not serve the ends of justice?
If the answer to all the steps is in the affirmative, judicial conscience of the High Court should persuade it to quash such criminal proceedings, in exercise of power vested in it under Section 482 of the Cr.P.C.”
Evaluating the facts against these parameters, the bench observed:
“Going through the averments, it is very clear that there was a consensual relationship between the parties.”
Regarding the first step, the bench pointed out that the material relied upon by the appellant clearly indicated money had been paid to the second respondent, which he claimed was pursuant to extortion, and that he had lodged two prior complaints with the jurisdictional police.
Examining the second step, the court observed:
“On step two, we have to specifically notice that admittedly there was a courtship and even according to the 2nd respondent she was raped against her will and then the desire to marry was put forth. No allegation of a promise to marry, proffered to entice the 2nd respondent into a sexual relationship, was raised. The specific allegation is that the petitioner was raped and, to desist her from reporting the same, the desire to marry was expressed, which was voluntarily and willingly accepted. The allegation of rape, hence, is delayed by more than one and a half years.”
The bench further highlighted that the alleged assault in a hotel room was never reported to the police by either the hotel staff or the complainant, nor were the alleged threats by the appellant’s relatives reported at the time. Crucially, the court noted:
“The complaint was filed specifically to coerce the appellant into marrying the complainant, failing which she wanted punitive action taken for the sexual assault and the exploitation. We also notice that the 2nd respondent though she asserts that twice her pregnancy was aborted, there is nothing indicated in the medical report to that end.”
On the fourth step, the bench formed a definite opinion that “no purpose would be served in carrying out a trial.”
Decision of the Court
The Supreme Court concluded that the High Court ought to have invoked its inherent powers under Section 482 of the Cr.P.C. to quash the criminal case. Accordingly, the Court set aside the impugned High Court order and quashed Charge Sheet No. 5 of 2026, dated January 19, 2026, in Criminal Case No. 147 of 2026 pending before the Court of Chief Judicial Magistrate, Ambikapur, District Sarguja.
The bench directed that no criminal proceedings shall continue either against the appellant or any other accused arrayed under the FIR, observing that allegations of hurt and criminal intimidation against other accused failed to impress the Court. Additionally, the bench directed that further proceedings regarding the appellant’s complaints (Annexure P1 and Annexure P2) need not be pursued.
Concluding the matter, the Court recorded:
“We pass these consequential directions only since we are convinced that there had been a consensual relationship between the parties which went sour and then each started accusing the other.”
With these observations, the appeal was allowed, and all pending applications were rejected.
Case Title: Sachin Gupta v. The State of Chhattisgarh and Anr.
Case No.: Criminal Appeal No. 4721 of 2026 (@Special Leave Petition (Crl.) No(s). 4615 of 2026)
Bench: Justice J. B. Pardiwala and Justice K. Vinod Chandran
Date: October 01, 2026
