Delhi High Court Quashes FIR Against Parag Prakash Rudrangi in Alleged Rape Case

Court Cites Lack of Corroborating Evidence and Implausible Allegations in Long-term Consensual Relationship

In a significant ruling, the Delhi High Court has quashed the FIR against Parag Prakash Rudrangi, accused of rape and unnatural sex on the false promise of marriage. The judgment, delivered by Justice Amit Mahajan, emphasizes the lack of corroborating evidence and inconsistencies in the complainant's statements as pivotal reasons for invoking the court's inherent jurisdiction under Section 482 of the Code of Criminal Procedure, 1973.

The case stemmed from a complaint filed by the woman, who alleged that Rudrangi had established a sexual relationship with her under the false pretext of marriage. According to her, the relationship commenced in June 2018 and continued until October 2018, during which Rudrangi allegedly extorted money from her and threatened to make intimate photos and videos viral.

However, the court noted that the complainant's statements were inconsistent, particularly concerning the timeline and nature of events. The judgment highlighted discrepancies between her FIR and statements recorded under Section 164 of the CrPC, raising doubts about the veracity of her claims. It was observed that the complainant reported the alleged rape months after the incident, following a fallout in the relationship, which further complicated her accusations.

The judgment underscored the importance of exercising inherent jurisdiction to prevent abuse of legal processes, particularly when allegations appear implausible. The court drew from precedents, including the Supreme Court's observations in similar cases, emphasizing that long-term consensual relationships cannot be construed as rape based on a false promise of marriage unless substantial evidence supports such claims.

Justice Mahajan remarked on the increasing misuse of legal provisions in cases of souring relationships, which poses a threat to genuine survivors and tarnishes reputations without cause. The court cautioned against weaponizing law for vengeance, underscoring the need for careful scrutiny of allegations, especially in matters involving sexual assault.

Despite the allegations of blackmail and forced unnatural sex, the court found no corroborative evidence to substantiate the claims. The judgment pointed to the absence of supporting material such as photographs, videos, or communications that would indicate coercion or deceit.

Ultimately, the court concluded that the proceedings were manifestly frivolous, warranting intervention to secure the ends of justice. The judgment serves as a reminder of the courts' role in balancing equities and protecting individuals from unwarranted criminal liability, especially in cases lacking credible evidence.

Bottom Line:

FIR and consequential proceedings quashed due to inherent jurisdiction of the Court under Section 482 of the CrPC, considering inconsistencies in complainant's statements, lack of corroborating evidence, and improbable allegations.

Statutory provision(s): Indian Penal Code, 1860 Sections 376, 328, 377, 506; Code of Criminal Procedure, 1973 Sections 164, 482

Parag Prakash Rudrangi v. State, (Delhi) : Law Finder Doc Id # 2804351