Supreme Court Exposes False Allegations, Quashes FIR in Sexual Assault Case

Facts Of The Case:

The case involves Batlanki Keshav (Kesava) Kumar Anurag, the appellant, challenging an order from the High Court for the State of Telangana at Hyderabad, which rejected his petition to quash FIR No. 103 of 2022. This FIR, registered at Madhapur Police Station, Cyberabad, alleges offenses under Section 376(2)(n) of the Indian Penal Code, 1860, and Section 3(2)(v) of the Scheduled Castes and the Scheduled Tribes (Prevention of Atrocities) Act, 1989The de-facto complainant (respondent No. 2) initially filed a complaint (FIR No. 751 of 2021) alleging the appellant promised marriage and later reneged, engaging in sexual intercourse without intent to marry. She claimed a written agreement was drawn where the appellant agreed to marry her. Subsequently, she filed another complaint (FIR No. 13 of 2021 in Kerala, later forwarded to Madhapur Police Station as FIR No. 103 of 2022) alleging multiple instances of sexual relations against her wishes and that the appellant refused to marry her, citing her lower caste.The appellant argued that the de-facto complainant is habitual of lodging such complaints, citing a previous similar complaint against another individual. He also presented evidence of the complainant’s manipulative and vindictive tendencies through call recordings and chats, suggesting she was using him and admitted to trying to “get a green card holder”. The appellant further contended that the multiple sexual encounters mentioned in FIR No. 103 of 2022 were not mentioned in the earlier FIR No. 751 of 2021, despite predating it, making the later allegations improbable

Procedural History:

The appellant challenged an order from the High Court of Telangana at Hyderabad, dated December 13, 2022, which had rejected his petition under Section 482 of the CrPC to quash FIR No. 103 of 2022. This FIR, registered at Madhapur Police Station, Cyberabad, alleged offenses under Section 376(2)(n) of the IPC and Section 3(2)(v) of the SC/ST (Prevention of Atrocities) Act. Previously, the de-facto complainant had filed FIR No. 751 of 2021 on June 29, 2021, for offenses under Sections 417 and 420 of IPC, where the appellant had secured anticipatory bail on September 30, 2021. FIR No. 103 of 2022 originated from a complaint initially filed in Kerala (FIR No. 13 of 2021), later transferred to Madhapur Police Station. The High Court, in disposing of the quashing petition for FIR No. 103 of 2022, directed the Investigating Officer to conclude the investigation without coercive steps against the appellant, provided he cooperated. The Supreme Court ultimately allowed the appeal, quashing both FIR No. 103 of 2022 and FIR No. 751 of 2021, and all subsequent proceedings.

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Court Observation:

The Court observed significant discrepancies between the two FIRs filed by the de-facto complainant. It noted that FIR No. 751 of 2021, dated June 29, 2021, alleged only a single sexual encounter on June 24, 2021. However, the impugned FIR No. 103 of 2022, lodged on February 1, 2022, referenced four to five incidents of sexual intercourse that purportedly occurred on May 4, 2021, May 11, 2021, May 28, 2021, and June 7, 2021—all predating the first FIR. The Court found it inherently improbable that the complainant, an educated 30-year-old woman, would have omitted these earlier incidents in her initial complaint if they had truly occurred under a false promise of marriage.Furthermore, the Court took into account that the de-facto complainant had a history of lodging similar complaints, as evidenced by a closure report in FIR No. 751 of 2021, which revealed a complaint filed on January 23, 2019, against an Assistant Professor at Osmania University with identical allegations of cheating and sexual exploitation under the pretext of a false promise of marriage. The Court also considered the undisputed evidence of call recordings and chat transcripts, which depicted the complainant’s manipulative and vindictive tendencies. In these chats, she referred to herself as “Muffin,” admitted to being manipulative, seeking a “green card holder,” and stated it would not be difficult to “trap the next one”. She also mentioned using the accused appellant. These observations led the Court to conclude that the allegations in FIR No. 103 of 2022 were “a bundle of lies full of fabricated and malicious unsubstantiated allegations”. The Court opined that continuing the prosecution would be a “travesty of justice” and a “gross abuse of the process of Court”

Final Decision & Judgement:

The Supreme Court of India, having considered the entirety of facts and circumstances, rendered a firm opinion that allowing the prosecution of the accused appellant to continue in the impugned FIR No. 103 of 2022 would constitute a travesty of justice and a gross abuse of the process of the Court. The Court characterized FIR No. 103 of 2022 as a “bundle of lies full of fabricated and malicious unsubstantiated allegations levelled by the complainant”. It highlighted that the facts on record clearly established the “vindictive and manipulative tendencies of the complainant,” which had a significant bearing on the controversy.Consequently, the Supreme Court allowed the appeal and quashed FIR bearing Crime No. 103 of 2022 dated February 1, 2022, FIR bearing Crime No. 751 of 2021 dated June 29, 2021, and all proceedings sought to be taken as a consequence thereof, in their entirety. Any pending applications were also disposed of. The judgment was delivered by Justices Vikram Nath and Sandeep Mehta on May 29, 2025

Case Details:

Case Title: BATLANKI KESHAV (KESAVA) KUMAR ANURAG VERSUS STATE OF TELANGANA & ANR. 
Citation: 2025 INSC 790 
Criminal Appeal No(s).: 2879 OF 2025
Date of Judgment: May 29, 2025 
Judges/Justice Name: Justice Vikram Nath and Justice Sandeep Mehta