Case at a glance: The Supreme Court has quashed a chargesheet alleging rape, promise to marry and related offences, holding that the material showed a consensual relationship that had soured, followed by accusations from both sides. Applying the four-step test in Pradeep Kumar Kesarwani, it noted the long delay, that the promise to marry was said to have come after the alleged rape, and that the medical report did not support the abortion allegations.
The appellant, a bank customer, met the complainant, a bank employee, through the bank. An FIR registered in December 2025 alleged rape in May 2024, a later promise to marry, two aborted pregnancies, and an assault and threats in a hotel room in October 2025 involving other accused.
The appellant said he had paid money under extortion and had already filed complaints against the complainant in November and December 2025, and called the FIR a counter-blast. The High Court declined to quash.
The Key Question Before the Court
Should the High Court have quashed the proceedings under Section 482 CrPC?
Applying Kesarwani and Rajiv Thapar
The Court applied the four steps from Pradeep Kumar Kesarwani v. State of UP, drawn from Rajiv Thapar v. Madan Lal Kapoor. The appellant's material—the payments and his earlier complaints—was sound and reliable.
The rape allegation came more than a year and a half later, and the promise to marry was said to have been made only after the alleged rape. The hotel assault and threats were never reported, and the medical report showed nothing about abortions. The Court concluded the relationship was consensual and had soured, after which each side accused the other, so a trial would serve no purpose.
What the Court Actually Held
- The chargesheet and Criminal Case No. 147/2026 before the CJM, Ambikapur were quashed.
- No criminal proceedings shall continue on the FIR against the appellant or any other accused.
- The hurt and intimidation allegations against the other accused were held not made out.
- The appeal was allowed.
Why This Judgment Matters
- It applies the structured Kesarwani test in a relationship-based rape case.
- It gives weight to the accused's prior complaints in showing a counter-blast.
- It extends relief to co-accused named in the same FIR.
What Should Advocates Take Away From the Judgment?
For Defence Counsel
- Place sound, unimpeachable material—earlier complaints, payment records—before the Court.
- Map the case onto the four Kesarwani steps.
For Complainants' Counsel
- Explain delay and support allegations with contemporaneous material.
Key Takeaways
- The four-step test was applied.
- The promise to marry came after the alleged rape.
- Medical evidence did not support the allegations.
- Proceedings quashed against all accused.
Frequently Asked Questions
A four-step inquiry into whether the accused's material is sound, rules out the accusations, is unrebutted, and whether trial would be an abuse of process.
They supported the appellant's case that the FIR was a counter-blast.
Yes. No proceedings are to continue against any accused on the FIR.
Conclusion
The judgment shows how the Supreme Court structures quashing analysis in disputes arising from failed relationships.
Practical takeaway: Strong documentary material from the accused can justify quashing at the threshold where the allegations do not hold together.