Summary and Analysis of Batlanki Keshav Kumar Anurag v. State of Telangana (2025 INSC 790)
Case Citation:
Criminal Appeal No. 2879 of 2025 (Arising out of SLP (Crl.) No. 3316 of 2023)
Decided on: May 29, 2025
Judges: Justice Vikram Nath, Justice Sandeep Mehta
Background and Procedural History:
FIRs Registered:
FIR No. 751 of 2021 (29.06.2021): Alleged sexual intercourse under false promise of marriage (Sections 417, 420 IPC).
FIR No. 103 of 2022 (01.02.2022): Enhanced allegations of rape (Section 376(2)(n) IPC) and caste-based discrimination (Section 3(2)(v) of SC/ST Act).High Court Order (2022):
Rejected the appellant’s plea to quash FIR No. 103/2022 but directed no coercive action during investigation.Supreme Court Appeal:
Quashed both FIRs, holding them as abuse of process due to inconsistencies and manipulative conduct by the complainant.
Key Issues Before the Supreme Court:
Whether the allegations of false promise of marriage and rape were substantiated by evidence.
Whether the subsequent FIR (No. 103/2022) was a vindictive escalation of allegations.
Whether the complainant’s habitual tendency to file similar complaints undermined her credibility.
Factual Matrix:
Parties:
Appellant (Accused): Batlanki Keshav Kumar, met complainant via matrimonial site; agreed to marry in 2021.
Complainant: 30-year-old educated woman from SC community.Allegations:
FIR No. 751/2021: Accused had one sexual encounter (24.06.2021) post-marriage promise but later avoided marriage.
FIR No. 103/2022: Accused raped her multiple times (May–June 2021) and cited her caste as reason for refusal.Defense:
Complainant had Obsessive Compulsive Disorder (OCD); manipulated accused via chats (e.g., "get a green card holder").
Prior Complaint (2019): Similar allegations against another man (Osmania University professor).
Supreme Court’s Analysis:
1. Inconsistencies in Complaints:
FIR No. 751/2021 mentioned only one incident (24.06.2021), while FIR No. 103/2022 alleged multiple incidents (May–June 2021).
Court: Omission of earlier incidents in the first FIR rendered subsequent claims inherently unreliable.
2. Complainant’s Credibility:
Chat Evidence: Complainant admitted to manipulative behavior (e.g., "trap the next victim").
Prior FIR (2019): Pattern of lodging similar complaints against men.
Court: Conduct indicated ulterior motives, not genuine grievance.
3. False Promise of Marriage:
Legal Principle: Mere breach of promise doesn’t constitute rape unless consent was vitiated by deception (Pramod Suryabhan Pawar v. State of Maharashtra).
Court: Complainant’s consensual relationship with accused was evident; no proof of coercion or caste-based discrimination.
4. Abuse of Process:
Quashing Standard (State of Haryana v. Bhajan Lal): FIRs lacking prima facie evidence or filed with malice must be quashed.
Court: FIR No. 103/2022 was a fabricated escalation to harass the accused.
Judgment:
Both FIRs Quashed:
No prima facie evidence of rape or caste-based offense.
Complainant’s habitual complaints and manipulative chats undermined her claims.Observations:
Courts must scrutinize delayed/escalated allegations to prevent misuse of SC/ST Act.
Educated adults in consensual relationships cannot later allege rape sans proof of coercion.
Key Precedents & Principles:
False Promise of Marriage:
Distinction between breach of promise and rape (Anurag Soni v. State of Chhattisgarh).Quashing FIRs:
Grounds for quashing (Bhajan Lal case): Frivolous claims, malice, or lack of evidence.SC/ST Act Misuse:
Allegations must show caste-based intent (Hitesh Verma v. State of Uttarakhand).
Final Order:
FIR Nos. 751/2021 and 103/2022 quashed.
All consequential proceedings annulled.
Conclusion:
The Supreme Court emphasized judicial vigilance against false rape cases stemming from failed relationships, especially where complainants exhibit manipulative tendencies. The judgment safeguards against weaponizing legal processes while upholding the sanctity of genuine grievances.
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