The Supreme Court of India, in a landmark ruling delivered on September 10, 2025, quashed a false rape case filed on the allegation of a promise of marriage, holding that continuation of such proceedings would amount to gross abuse of the process of law.
The judgment, delivered by a Bench comprising Justice JB Pardiwala and Justice Sandeep Mehta, is significant not only for its relief to the accused but also for the four-step test laid down for High Courts while exercising their inherent powers under Section 482 of the Code of Criminal Procedure (CrPC) (now Section 528 of the Bharatiya Nagarik Suraksha Sanhita).
This ruling in Pradeep Kumar Kesarwani v. State of Uttar Pradesh & Anr is expected to become a guiding precedent in cases involving false, frivolous, or vexatious complaints, particularly those alleging rape on the false pretext of marriage.
Case Background
The case dates back to 2014, when a woman filed a private complaint before the Additional Chief Judicial Magistrate, Allahabad. She alleged that the accused, whom she met in 2010 during coaching classes, had:
- Befriended her and engaged in sexual relations on the false promise of marriage.
- Recorded objectionable videos to blackmail her.
- Forced her to undergo an abortion in 2011 after she became pregnant.
- Subjected her to caste-based abuse with the support of his family when she pressed for marriage.
The complaint invoked serious charges under:
- Sections 323, 504, 376, 452, 377, and 120B of the IPC, and
- Scheduled Caste and Scheduled Tribe (Prevention of Atrocities) Act, 1989.
A Magistrate, after inquiry under Section 202 CrPC, took cognizance and summoned the accused for trial.
The accused challenged this before the Allahabad High Court in 2019 under Section 482 CrPC, but the High Court refused to quash the proceedings. This led to an appeal before the Supreme Court.
Supreme Court’s Observations
The apex court made several crucial observations:
- Frivolous Complaints Harm Reputations
The Court reiterated that summoning a person on frivolous or vexatious complaints is a serious matter because it damages the reputation and image of the accused. - Abuse of Process
The continuation of a doubtful case without concrete evidence amounts to abuse of the process of law and wastes judicial time. - Doubtful Complaint
The Bench noted that key details such as dates and places of alleged crimes were missing, and allegations were unsupported by independent evidence. - Complainant’s Conduct
Importantly, the complainant did not even accept the notice served by the Supreme Court, which indicated her lack of seriousness in pursuing the case. - Careful Approach in Rape on Promise of Marriage Cases
The Court stressed that in such cases, courts must carefully distinguish between:
- Genuine cases where the accused never intended to marry and deceived the victim, and
- Cases where a relationship failed for genuine reasons without criminal intent.
- Dragging Parents Into the Case
The Court also criticized the inclusion of the accused’s parents in the case, terming it unnecessary harassment.
The Four-Step Test Laid Down
In a landmark move, the Supreme Court formulated a four-step test for High Courts while exercising inherent powers under Section 482 CrPC (Section 528 BNSS).
The Court said High Courts should ask:
- Quality of Evidence
Whether the material relied upon by the accused is sound, reasonable, and of sterling quality? - Impact on Charges
Whether such material negates the factual assertions in the complaint, making the allegations unsustainable for a reasonable person? - Refutability
Whether the prosecution has failed to refute the accused’s material, or whether such material is incapable of refutation? - Ends of Justice
Whether continuation of the trial would amount to abuse of the process of court and fail to serve the ends of justice?
If the answer to all four questions is yes, the High Court should quash the criminal proceedings.
Significance of the Ruling
This judgment has wide-ranging implications:
- For the Accused: It safeguards individuals from malicious prosecution and protects their reputations.
- For the Judiciary: It provides High Courts with a structured framework to assess frivolous complaints, reducing unnecessary trials.
- For Society: It highlights the dangers of false allegations of rape, which not only harm the accused but also dilute the seriousness of genuine cases.
- For Women’s Rights: While cautioning against misuse, the Court reiterated that genuine cases of sexual assault must be pursued seriously, striking a balance between justice for victims and protection against false cases.
Criticism of Lower Court’s Approach
The Supreme Court also criticized the Allahabad High Court’s 2019 decision, which had dismissed the quashing plea without adequately scrutinizing the complaint’s credibility.
By failing to intervene, the High Court subjected the accused to years of unnecessary trial, which the Supreme Court has now corrected.
Representation in Court
- For the Accused: Senior Advocate Rahul Kaushik, along with advocates Bibek Tripathi, Y Lokesh, Sudhakar Tiwari, Ajay Kumar Shrivastav, Mohit Kumar Gupta, and Akshat Srivastava.
- For the Respondents: Advocates Adarsh Upadhyay, Pooja Singh, Pallavi Kumari, and Shashank Pachauri.
Conclusion
The Supreme Court’s decision in Pradeep Kumar Kesarwani v. State of Uttar Pradesh & Anr is a significant milestone in India’s criminal jurisprudence. By quashing a false rape case based on the promise of marriage and laying down a four-step test, the Court has struck a balance between protecting the rights of accused persons and preventing misuse of criminal law, while still ensuring that genuine victims receive justice.
This judgment will serve as a guiding precedent for High Courts dealing with frivolous, malicious, or vexatious prosecutions under Section 482 CrPC, ensuring that the criminal justice system is not weaponized for personal vendetta.
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