The Supreme Court of India quashed criminal proceedings against the Appellant, finding that the alleged sexual assault and unnatural sex charges under Sections 376, 376(2)(n), 377, 504, and 506 of the IPC were not established. The Court held that the relationship was consensual, not based on a false promise to marry, and the complaint was likely motivated by a “disgruntled state of mind”. The case fell under categories for quashing criminal proceedings to prevent abuse of process of law.
Facts Of The Case:
This appeal arises from the dismissal of Amol Bhagwan Nehul’s petition to quash Criminal Case C.R. No. 490/2023, registered on July 31, 2023, for alleged offenses under Sections 376, 376(2)(n), 377, 504, and 506 IPC. The Complainant, Respondent No. 2, alleged that the Appellant forcibly had sexual intercourse with her between June 8, 2022, and July 8, 2023, under a false assurance of marriage. She claimed that despite her denials, the Appellant had sexual intercourse with her in July 2022, and subsequently on September 21, 2022, and in January 2023, where unnatural sex was also alleged, all on the promise of marriage. The Complainant, a previously married woman with a 4-year-old son, had obtained a Khulanama from her ex-husband. The Appellant, a student and neighbor, denied the allegations, stating the Complainant harassed him and threatened false rape cases. His father also filed a complaint alleging harassment. The Appellant was granted anticipatory bail, with the Additional Sessions Judge noting the Complainant was a mature consenting party.
Procedural History:
The procedural history of this case began with the registration of Criminal Case C.R. No. 490/2023 on July 31, 2023, at Karad Taluka Police Station, Satara, based on a complaint filed by Respondent No. 2. The Appellant, Amol Bhagwan Nehul, sought anticipatory bail from the Additional Sessions Judge, Karad, which was granted on August 23, 2023. Subsequently, the Appellant preferred Criminal Writ Petition No. 3181 of 2023 before the High Court of Judicature at Bombay, seeking to quash C.R. No. 490/2023 and the proceedings emanating therefrom. While this petition was pending, the investigation culminated in a charge-sheet filed on September 26, 2023, before the Additional Sessions Judge, Karad, and proceedings in RCC No. 378/2023 commenced. The High Court dismissed the Appellant’s petition via an order dated June 28, 2024. The Appellant then brought the matter before the Supreme Court of India via a special leave petition, which was converted into Criminal Appeal No. of 2025 (arising out of SLP (Crl.) No. 10044 of 2024). The Supreme Court ultimately allowed the appeal, setting aside the High Court’s order and quashing the criminal proceedings.
READ ALSO :Supreme Court Protects Victim’s Rights: No Jail for Accused in POCSO Case
Court Observation:
The Supreme Court observed that even accepting the FIR’s allegations, the Complainant’s consent did not appear to be obtained against her will or merely by an assurance to marry, noting she sustained the relationship for over 12 months and visited him in lodges, which contradicted her claims. The Court found no material to substantiate “inducement or misrepresentation” for sexual relations without intent to fulfill a promise, especially since the Complainant obtained her Khulanama after the alleged incidents. It deemed it improbable that a previously married woman would continue a prolonged relationship with someone who sexually assaulted her. The Court concluded this was not a case of a false promise to marry initially, warning against using criminal machinery for consensual relationships that turn sour, as it burdens courts and harms the accused’s reputation. The ingredients for offenses under Sections 376(2)(n) or 506 IPC were not established.
Final Decision & Judgement:
The Supreme Court, in its final decision, allowed the appeal, setting aside the Impugned Order dated June 28, 2024, passed by the High Court of Judicature at Bombay in Crl. W.P. No. 3181 of 2023. Consequently, C.R. No. 490/2023 dated July 31, 2023, registered at Karad Taluka Police Station, Satara, and all proceedings emanating therefrom, including RCC No. 378/2023 pending before the Additional Sessions Judge, Karad, were quashed. The Appellant was discharged, and any bail bonds furnished were cancelled. The Court emphasized that it was in the interest of justice that the Appellant, being only 25 years old, should not suffer an impending trial. The decision was delivered on May 26, 2025
Case Details:
Case Title: Amol Bhagwan Nehul Versus The State of Maharashtra & Anr. Citation: 2025 INSC 782 Appeal No.:Arising out of SLP (Crl.) No. 10044 of 2024) Date of Judgment: May 26, 2025 Judges/Justice Name: Justice B.V. Nagarathna & Justice Satish Chandra Sharma
Download The Judgement Here