Supreme Court of India.
Case Laws against false rape complaints: Supreme Court Lays Four-Step Test to Identify Frivolous Criminal Complaints: In a landmark decision, the Supreme Court has quashed a false rape case that was lodged on the false promise of marriage, asserting that continuing with the criminal proceedings would amount to a severe abuse of the legal process. The case, Pradeep Kumar Kesarwani v. The State of Uttar Pradesh & Anr., saw a Bench comprising Justice JB Pardiwala and Justice Sandeep Mehta set down a crucial four-step test to guide High Courts when considering requests to quash frivolous or vexatious criminal complaints.
A Serious Matter: Protecting Reputation and Judicial Resources
The Court made it clear that summoning an individual based on a frivolous complaint not only damages the reputation of the accused but also wastes valuable judicial time. Reiterating that such allegations should be taken very seriously, the Court observed that false and unfounded claims have the potential to tarnish an individual’s name irreparably.
In this case, the man was accused of raping a woman under the false pretext of marriage. The woman claimed that the accused had befriended her during coaching classes in 2010, sexually assaulted her, filmed the act to blackmail her, and later coerced her into an abortion. She also accused his family of caste-based abuse when she pressed him to marry her.
The case had been initially registered in 2014, with the accused facing serious charges under various sections of the Indian Penal Code (IPC), including rape, criminal conspiracy, and house trespass, as well as allegations under the Scheduled Caste and Scheduled Tribe (Prevention of Atrocities) Act.
The Four-Step Test: A New Legal Framework
In its judgment, the Supreme Court established the following four-step test to help High Courts assess whether criminal proceedings should be quashed:
Quality of Evidence: Whether the material presented by the accused to support the request for quashing is sound, reasonable, and indisputable.
Factual Rejection: Whether the material presented is sufficient to negate the charges made in the criminal complaint to the extent that a reasonable person would dismiss the accusations as false.
Non-Refutation by Prosecution: Whether the material provided by the accused has not been successfully challenged or refuted by the prosecution or complainant.
Abuse of Judicial Process: Whether continuing the trial would constitute an abuse of the court’s process and fail to serve the ends of justice.
If the answer to all four aspects is in the affirmative, the Court stated that the judicial conscience of the High Court should persuade it to quash the criminal proceedings.
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Allahabad High Court.
Allahabad High Court’s Rejection Reversed
The Supreme Court‘s ruling came after the Allahabad High Court in 2019 had dismissed the accused’s plea to quash the proceedings. The man then moved the Supreme Court, contending that the criminal complaint against him was vague and amounted to an abuse of the judicial system.
Upon reviewing the case, the Supreme Court found several inconsistencies, including the absence of key details like the date and location of the alleged incidents. Additionally, the complainant failed to present any independent evidence to substantiate her allegations. In a critical observation, the Court noted that the complainant had refused to accept notice from the Supreme Court, which further suggested a lack of seriousness in pursuing the matter.
The Court also pointed out that the complainant’s claim that the accused had made a false promise of marriage to exploit her sexually required a careful legal examination. The Court emphasized that claims of rape based on a false promise of marriage must be scrutinized with particular attention to the accused’s actual intent and whether the promise was made with malice or deceit.
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Tarnishing Family Reputation: A Notable Observation
In an important remark, the Court took note of the fact that the accused’s family had been unjustly dragged into the case. The complaint included allegations against the accused’s parents, which the Court found to be a misuse of the legal system.
Justice Served, Court Resources Protected
The Supreme Court concluded that continuing with the criminal case would be an unjustified drain on the judicial system and a gross abuse of the legal process. The criminal proceedings were therefore quashed, providing a much-needed safeguard for individuals facing baseless allegations.
The decision marks a significant step in curbing the misuse of the judicial system through frivolous complaints, underscoring the need for a more discerning approach in cases involving serious charges such as rape.
Key Legal Representation
Senior Advocate Rahul Kaushik, along with advocates Bibek Tripathi, Y Lokesh, Sudhakar Tiwari, and several others, represented the accused. On the other side, advocates Adarsh Upadhyay, Pooja Singh, Pallavi Kumari, and Shashank Pachauri appeared for the respondents.
This case reinforces the Court’s commitment to ensuring that the legal process is not abused, and serves as a crucial reminder of the need for fair and thorough examination in criminal cases.
