Introduction

In a significant ruling delivered on May 29, 2025, the Supreme Court of India has quashed two First Information Reports (FIRs) filed against an individual accused of false promise of marriage, sexual exploitation, and caste-based discrimination. The case, identified as Criminal Appeal No(s). 2879 of 2025, involved appellant Batlaniki Keshav (Kesava) Kumar Anurag and respondent State of Telangana & Anr. This judgement, authored by Justices Vikram Nath and Sandeep Mehta, highlights the importance of credible evidence and the misuse of legal processes in cases involving personal disputes. For the common person, this case serves as a reminder of how the judiciary balances individual rights with the need to prevent abuse of the law.

Background of the Case

The dispute originated when the de-facto complainant (respondent No. 2) alleged that the appellant, whom she met through the Bharath Matrimony website, promised to marry her but later reneged. The complainant claimed that the appellant engaged in sexual intercourse with her under the false promise of marriage, an offense under Section 376(2)(n) of the Indian Penal Code (IPC), and further accused him of caste-based discrimination under Section 3(2)(v) of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989.

Two FIRs were filed: FIR No. 751 of 2021 on June 29, 2021, at Madhapur Police Station, and FIR No. 103 of 2022 on February 1, 2022, after the case was transferred. The appellant sought to quash these FIRs under Section 482 of the Code of Criminal Procedure (CrPC), arguing that the allegations were fabricated and motivated by personal vendetta. The High Court of Telangana had earlier rejected his petition, leading to an appeal in the Supreme Court.

Key Facts and Allegations

The complainant alleged that after an initial agreement to marry—sealed with a written commitment—the appellant and his mother began avoiding wedding arrangements. She claimed that on June 24, 2021, the appellant forced her into sexual intercourse without intending to marry her. Later, in FIR No. 103 of 2022, she expanded her claims, alleging multiple instances of sexual exploitation between May and June 2021, citing the appellant’s refusal to marry her due to her caste.

The appellant countered these allegations by presenting evidence, including call recordings and photographs, suggesting the complainant suffered from Obsessive Compulsive Disorder (OCD) and had manipulative tendencies. He argued that any physical relations were consensual and that the complainant had a history of filing similar complaints, including against an Assistant Professor at Osmania University in 2019.

Supreme Court’s Analysis

The Supreme Court meticulously examined the evidence. A critical observation was the inconsistency between the two FIRs: FIR No. 751 of 2021mentioned only one incident, while FIR No. 103 of 2022 listed multiple prior incidents, which the court found improbable for the complainant to omit earlier. The court also noted a closure report in FIR No. 751 of 2021 and a chargesheet in FIR No. 103 of 2022, but found the latter lacking credible evidence of deception or caste-based intent.

Transcripts of chats revealed the complainant admitting to manipulative behavior, including plans to “trap” others for personal gain, such as a green card. The court concluded that the appellant’s decision to back out of the marriage was justified given the complainant’s aggressive behavior, and there was no proof of false promise of marriage or caste discrimination.

The Verdict

In a landmark decision, the Supreme Court quashed both FIRs, deeming the prosecution a gross abuse of process. The judgement emphasized that continuing the case would be a travesty of justice, given the lack of prima facie material and the complainant’s apparent vindictive motives. This ruling underscores the judiciary’s role in protecting individuals from baseless legal harassment while ensuring genuine cases are pursued.

Implications for the Layman

This case is a wake-up call for anyone involved in personal disputes that escalate to legal battles. It highlights that:

1. False allegations can be challenged with evidence like recordings or documents.
2. The courts scrutinize inconsistencies in complaints to prevent misuse of laws like the IPC or SC/ST (POA) Act.
3. Consent and intent are key factors in cases of sexual exploitation under a false promise of marriage.

For the average person, this judgement reinforces the need for honesty and evidence in legal matters, protecting the innocent from fabricated claims while upholding justice.

Conclusion

The Supreme Court of India’s ruling on May 29, 2025, in the Batlaniki Keshav (Kesava) Kumar Anurag vs. State of Telangana case sets a precedent for handling cases involving false promise of marriage, sexual exploitation, and caste-based allegations. By quashing the FIRs, the court has sent a strong message against the misuse of legal mechanisms, ensuring that justice prevails only with credible evidence. This decision is a beacon for individuals navigating the complexities of personal and legal disputes in India.