Supreme Court Quashes Rape and SC/ST Atrocities FIR, Terms Allegations as Fabricated and Vindictive

A Bench of Justice Vikram Nath and Justice Sandeep Mehta of the Supreme Court has quashed an FIR filed under Sections 376(2)(n) IPC and 3(2)(v) of the SC/ST (Prevention of Atrocities) Act, 1989, against the appellant Batlanki Keshav (Kesava) Kumar Anurag, terming the allegations made by the complainant as “a bundle of lies full of fabricated and malicious unsubstantiated allegations.”

Background

The appellant had challenged the 13 December 2022 order of the Telangana High Court that declined to quash FIR No. 103 of 2022 registered at Madhapur Police Station, Cyberabad. The FIR alleged that the appellant had engaged in repeated sexual intercourse with the complainant on the false promise of marriage and subsequently refused to marry her due to her caste.

An earlier FIR (Crime No. 751 of 2021) had been lodged by the same complainant, alleging that the appellant had coerced her into a sexual relationship on 24 June 2021 and later refused to marry her. The High Court, while disposing of the appellant’s quashing petition, directed the police to continue the investigation but restrained them from taking coercive action.

Arguments

For the Appellant:
The counsel for the appellant argued that the second FIR was an exaggerated and vindictive version of the first. It was pointed out that while FIR No. 751 of 2021 mentioned only a single incident, the later FIR claimed multiple instances of sexual assault that allegedly occurred even before the date of the first FIR. The appellant’s counsel also placed reliance on transcripts of chats and call recordings suggesting that the complainant suffered from obsessive compulsive disorder and had a history of manipulative conduct. A prior similar FIR filed by the complainant in 2019 against another individual was also cited.

For the State:
The State opposed the petition, asserting that serious allegations of sexual assault were levelled and that the FIR should be investigated fully.

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Court’s Observations

The Supreme Court noted the contradiction between the two FIRs. It highlighted that all the alleged incidents in the second FIR predated the filing of the first FIR, yet no reference to them was made earlier. The Bench observed:

“It is thus inherently improbable that the complainant would have forgotten or omitted to mention these incidents of sexual intercourse made under a false promise of marriage while filing the earlier FIR.”

The Court also scrutinised chat transcripts where the complainant, referred to as “Muffin,” admitted to manipulating men and seeking a “green card holder.” These, the Court held, “depict the stark reality about the behavioral pattern of the de-facto complainant who appears to be having manipulative and vindictive tendency.”

Rejecting the claim of caste-based discrimination, the Court found that no mention of caste was made in the earlier FIR, concluding:

“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.”

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Decision

Holding that the continuation of prosecution would amount to a travesty of justice and gross abuse of the process of the Court, the Supreme Court quashed FIR No. 103 of 2022, FIR No. 751 of 2021, and all consequential proceedings. The appeal was allowed accordingly.


Case Title: Batlanki Keshav (Kesava) Kumar Anurag vs State Of Telangana & Anr.
Criminal Appeal No.: 2879 of 2025 (Arising out of SLP (Crl.) No. 3316 of 2023)

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