supreme court justice anirudh mehta quashes dual firs, declaring criminal proceedings vexatious in high-profile deceit case
Introduction
Criminal Appeal No. 2879 of 2025 was heard by a panel of two judges from the Supreme Court of India on May 29, 2025. Justice Anirudh Mehta presided over the bench, which was responsible for delivering its ruling.
An ruling issued by the Telangana High Court that declined to cancel a First Information Report (FIR) accusing the appellant with violating Section 376(2)(n) of the Indian Penal Code and Section 3(2)(v) of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989 was the impetus for the appeal.
The appellants, Batlanki Keshav (Kesava) Kumar Anurag, challenged the proceedings as an abuse of the legal process. They did so by relying on the inherent powers of the High Court, which are outlined in Section 482 of the Code of Criminal Procedure, 1973.
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Background of the Relationship
During the time that the appellant was living in the United States, the de facto complainant met the appellant via an online matrimonial agency. This is when the conflict really started. It was agreed that they would be married on January 6, 2021; but, according to her subsequent allegation, the appellant went back to another country without keeping their agreement to get married.
Subsequent to his return to India, sexual contacts took place on many occasions between the months of May and June 2021. between these times, she claimed that he had tricked her by making a fake promise of marriage.
Due to the occurrence of these occurrences, two different First Information Reports (FIRs) were filed at the Madhapur Police Station in Cyberabad.
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Legal Charges and FIRs
Based on a single event that occurred on June 24, 2021, the first First Information Report (Crime No. 751 of 2021) presented allegations of cheating and criminal breach of trust in accordance with Sections 417 and 420 of the Indian Penal Code.
A closure report was eventually produced by the police in that particular instance. The allegations were expanded to include four separate incidents of sexual intercourse that occurred between May 4 and June 7, 2021, and additional charges were added under Section 376(2)(n) of the Indian Penal Code (sexual assault by deceit) and Section 3(2)(v) of the SC/ST (POA) Act for caste-based atrocity.
According to the second First Information Report (Crime No. 103 of 2022), the allegations were expanded.
Petition for Quashing under Section 482 CrPC
The appeal that the appellant submitted to the Telangana High Court was filed under Section 482 of the Criminal Procedure Code. The appellant claimed that the two FIRs were malicious and inconsistent.
In his argument, he said that there was a lack of prima facie evidence since there were inconsistencies in the dates and the complainant had a history of filing complaints that were similar to the one being filed. In addition to this, he relied on call records and images to support his claim that the complainant was a victim of obsessive-compulsive disorder and had manipulative behavioral patterns.
High Court’s Decision
The second First Information Report (FIR) was not dismissed by the High Court on December 13, 2022. It made the observation that the complainant and the appellant had not lived together after the first FIR, and it instructed the police to finish the inquiry without resorting to any coercive means while simultaneously guaranteeing that the appellant would cooperate for the investigation.
It was emphasized that the sexual assault and atrocity allegations were quite serious, thus the court decided not to evaluate the merits of the case at that point.
Supreme Court’s Analysis
In his argument, the attorney for the appellant argued that the first and second FIRs were incompatible with one another. He brought attention to the fact that the first lawsuit, which was filed on June 29, 2021, would have contained many instances of dishonesty if they had really taken place.
Under the pretext of criminal procedures, he claimed that the ensuing FIR was a premeditated ploy to prolong harassment. He maintained that this was the case. On the other side, the State stated that the charges were serious and deserving of a comprehensive examination, especially in light of the charge of atrocity based on caste.
Contradictions and Improbabilities
Following an examination, the Supreme Court identified two significant aspects. In the first place, the closure report in FIR No. 751 of 2021 and the chargesheet in FIR No. 103 of 2022 indicated that the police itself judged the prior allegations to be baseless, yet they continued with new accusations after a break of seven months. Second, the court determined that there was no prima facie evidence to establish cheating by false promise of marriage or caste-based atrocities.
This was due to the fact that the original FIR did not include any references to caste discrimination, and the complainant herself admitted in call recordings that she engaged in manipulative conduct.
Role of Investigations and Closure Report
The court emphasized the glaring discrepancy that the first FIR only reported a single interaction, whereas the second FIR revealed four previous incidents—events that occurred before the first FIR but were not included in it.
The ensuing complaint’s credibility was damaged as a result of this omission, which was intrinsically implausible. A history of making false or exaggerated charges was further evidenced by the fact that the complainant had previously filed a complaint against another person that was nearly similar to the one that was presented here.
Abuse of Process and Malicious Allegations
An essential part was performed by the documents of the investigation. According to the report that was used to close the first FIR, there were no grounds for pursuing. Therefore, the claims had not been put to the test since the subsequent chargesheet that was included in the second FIR had not yet resulted in a trial.
It was decided by the Supreme Court that it would be unreasonable to permit lengthy criminal processes in which the basic allegations had any prima facie basis. This was particularly true since the police had previously closed an earlier case that was almost similar to the one that was being investigated.
Quashing Judgment and Its Implications
“A travesty of justice” and a “gross abuse of process” are two words that Justice Mehta used to describe the contested First Information Reports. He came to the conclusion that the whole procedure was “a bundle of lies full of fabricated and malicious unsubstantiated allegations” that were intended to torment the candidate for the appellate position.
In its decision, the court determined that the complainant’s spiteful inclinations, which were shown by her texts in which she described her intention to “trap” many individuals, rendered any assumption of good faith in her claims null and void.
Both the First Information Report (FIR) No. 751 of 2021 and the FIR No. 103 of 2022 were completely dismissed by the Supreme Court after it granted the appeal. It issued a directive that the matters would not be subject to any further proceedings.
As a result of the ruling, the inherent powers granted to the High Court by Section 482 of the Criminal Procedure Code to prohibit abuse of the legal process and to protect persons from vexatious litigation without prima facie evidence were confirmed.
In addition, it made it clear that charges of sexual assault by deception and atrocities based on caste must be supported by evidence that are trustworthy and consistent before criminal cases may begin.
Conclusion
The ruling that was handed down by the Supreme Court in the case of Batlanki Keshav Kumar Anurag vs. State of Telangana may be seen as an important affirmation of the responsibility of the judiciary to prevent malicious prosecutions.
The Court highlighted the need of striking a balance between protecting persons from harassment via manufactured charges and ensuring that real victims have access to justice by dismissing First Information Reports (FIRs) that showed a lack of prima facie substance.
Therefore, the decision made by Justice Mehta serves as a precedent for the careful examination of contradictory complaints and the aggressive application of Section 482 of the Criminal Procedure Code in order to maintain the integrity of criminal jurisprudence.
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