Rape on pretext of marriage - Complaint filed with ulterior motives for vengeance after adverse consequences at workplace, Quashed
Supreme Court Quashes Rape Charges on Pretext of Marriage in Landmark Judgment. FIR and Charge-Sheet Quashed Due to Ulterior Motives; Supreme Court Highlights Abuse of Legal Process
In a significant judgment delivered by the Supreme Court of India, the FIR and charge-sheet filed against Surendra Khawse, accused of rape on the pretext of marriage, have been quashed. The ruling was delivered by the bench comprising Justice Sanjay Karol and Justice Nongmeikapam Kotiswar Singh on 22nd September 2025. This decision came as the apex court scrutinized the circumstances surrounding the filing of the complaint and found it to be driven by ulterior motives.
The case revolved around an alleged incident where the complainant accused Khawse of forcing intimate relations under the false promise of marriage. However, the Supreme Court observed that the FIR was lodged post issuance of a show-cause notice to the complainant by her employer, indicating potential vengeful motives after facing adverse consequences at her workplace. This delay in filing the complaint, along with the surrounding circumstances, led the court to deem the proceedings frivolous and vexatious.
The judgment underscored the importance of exercising inherent powers under Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023, corresponding to Section 482 of the Criminal Procedure Code, 1973. The court reiterated that these powers must be used judiciously, particularly when criminal proceedings appear to be instituted with malicious intent. The bench drew on established legal principles from landmark cases such as State of Haryana v. Bhajan Lal and Mohd. Wajid v. State of U.P., emphasizing the need for courts to examine the FIR closely and consider all attending circumstances.
Justice Karol, while delivering the judgment, noted that the complainant's actions seemed retaliatory, initiated after the appellant had taken administrative action against her. The Supreme Court's ruling sets a precedent for similar cases, highlighting the judiciary's role in preventing the abuse of legal processes and ensuring justice is served without prejudice.
Bottom Line:
Supreme Court quashed the FIR and charge-sheet in a case of alleged rape on the pretext of marriage, observing that the complaint was filed with ulterior motives and as a vehicle for vengeance after the complainant faced adverse consequences at her workplace.
Statutory provision(s): Bharatiya Nagarik Suraksha Sanhita, 2023 Section 528, Criminal Procedure Code, 1973 Section 482
Surendra Khawse v. State of Madhya Pradesh, (SC) : Law Finder Doc id # 2782732
