Recently, the Supreme Court in the judgement quashed all FIR’s made by complainant, as it was misleading and manipulative to the appellant. The case focuses on the false complaint of cheating and sexual harassment made on appellant by complainant. This case shows the misuse of Legal Process in false sexual offence allegation made by one of the parties to another. The Court ruled that allowing the prosecution to continue would be a “travesty of justice” and emphasized that the appellant was justified in withdrawing from the marriage upon discovering the complainant's obsessive and manipulative behaviour, thereby protecting innocent individuals from vindictive prosecutions while maintaining the integrity of the criminal justice system.
Brief Facts:
The complainant, a 30-year-old educated woman, alleged that the appellant had sexual relations with her under a false promise of marriage and later refused to marry her on grounds of caste. She initially filed an FIR alleging a single instance of sexual intercourse; however, in a subsequent FIR, she claimed multiple such incidents had occurred earlier as well. It was revealed that she had filed a similar complaint in 2019 against one Dr. Ranjit Thankappan, an Assistant Professor at Osmania University. Further, chat transcripts submitted to the Court revealed that the complainant had openly admitted to being manipulative, targeting Green Card holders, and planning to entrap men.
The appellant asserted that the complainant had fabricated the allegations and had pressured him into a relationship through threats of self-harm and emotional blackmail.
Contention of Appellant(s):
The counsel for the appellant argued that the FIRs were false, exaggerated, and inconsistent. He submitted that the complainant had a history of filing similar allegations against others, including the 2019 case involving Dr. Thankappan. It was contended that the complainant's intent was to harass and coerce the appellant. Chat messages and call recordings were placed on record to show that the complainant was manipulative, vindictive, and had admitted to targeting men for personal gain. The second FIR was described as an afterthought, containing allegations not mentioned in the first. The appellant maintained that the relationship was consensual and not induced by deception.
Contention of Respondent(s):
The State opposed the plea for quashing, arguing that the FIR disclosed cognizable offences under Section 376(2)(n) IPC and Section 3(2)(v) of the SC/ST Act. It was contended that the appellant had engaged in repeated sexual intercourse on a false promise of marriage and later refused to marry due to caste considerations. The State submitted that the allegations were serious and required investigation, and that quashing the FIR at this stage would defeat the complainant’s right to legal recourse. It supported the High Court’s decision to allow the investigation to proceed.
Observations of the Court:
The Court critically examined the credibility of the complainant, a well-educated 30-year-old woman, noting that she filed multiple FIRs containing significant contradictions. The Court found it highly unlikely that someone with her level of legal awareness would omit such serious allegations initially and add them months later, casting doubt on the authenticity of her claims. It further pointed out the complainant’s established pattern of similar accusations, referencing a nearly identical case filed in 2019 against Dr. Ranjit Thankappan, an Assistant Professor at Osmania University. The Court concluded, that this reflected a clear modus operandi of targeting educated, professional men with fabricated allegations of sexual exploitation under the false promise of marriage. Such repetitive behaviour, showed a deliberate abuse of the legal process rather than isolated incidents.
The Court took strong note of chat conversations where the complainant, referring to herself as “Muffin,” admitted to targeting Green Card holders and provoking breakups to repeat the cycle. These messages, coupled with call recordings, were held to be strong evidence of her calculated and vindictive conduct. Additionally, the Court found the allegations of caste-based discrimination to be a clear afterthought, introduced only in the second FIR, filed nearly eight months after the first. It held that this pointed to a deliberate misuse of protective legal provisions under the SC/ST Act. The Court also criticized the complainant’s conduct of filing cases in different jurisdictions as a tactic of forum shopping to harass the appellant.
The Court called this a blatant abuse of the legal process, warning that such actions harm genuine victims and undermine public trust in the justice system. Labelling the case a "bundle of lies" and a "travesty of justice," the Court quashed all proceedings, stressing the importance of safeguarding the rights of the accused and preserving the credibility and integrity of judicial institutions.
The decision of the Court:
The Top Court, allowed the appeal and quashed both FIRs in their entirety, along with all consequential proceedings. The Court held, “that allowing the prosecution to continue would be nothing short of a travesty of justice and would constitute a gross abuse of the process of the Court”. The Court held, “The impugned FIR No. 103 of 2022 is nothing but a bundle of lies full of fabricated and malicious unsubstantiated allegations levelled by the complainant”.
Case Title: Batlanki Keshav Kumar Anurag v. State of Telangana (2025)
Case No: Criminal Appeal No(s). 2879 of 2025
Coram: Justice Vikram Nath and Justice Sandeep Mehta.
Picture Source :