Beneath the Veil of Consent: High Court Quashes ‘Honey Trap’ Rape Allegations

In a significant ruling that underscores the judiciary’s role in preventing the abuse of the legal process, the High Court of Gujarat has set aside an FIR alleging rape under Section 376(1) of the Indian Penal Code (IPC). Justice M. K. Thakker, presiding over the matter, characterized the dispute as a calculated case of "honey trapping" rather than a genuine criminal offence.

The Trajectory of a Disputed Relationship

The case stemmed from a 2021 FIR filed by a 38-year-old beauty parlour owner against the petitioner, Manojbhai Kachrabhai Vasoya. According to the informant’s account, their relationship began via a Facebook friend request in 2019, eventually leading to multiple meetings at various locations. The complainant alleged that she was drugged and assaulted on multiple occasions by the petitioner.

However, the accused painted a vastly different picture, arguing that the relationship was entirely consensual and that the FIR was a weaponized response to his refusal to succumb to extortion demands totaling ₹60 lakhs and his wife’s jewelry.

Arguments from the Bar

Counsel for the petitioner relied heavily on the landmark Supreme Court decision in State of Haryana vs. Bhajanlal , arguing that the FIR failed to disclose the commission of any cognizable offence and was clearly motivated by personal grudge and mala fide intent. The petitioner submitted evidence, including transcripts of telephonic conversations, to demonstrate that the complainant had been actively soliciting money.

Conversely, the State argued that because the investigation was ongoing and a statement under Section 164 of the CrPC had been recorded by the victim, the Court should refrain from intervening before the filing of a chargesheet.

The Judiciary’s Scrutiny

Justice Thakker observed that the factual narrative presented by the informant strained credulity. The court noted that the complainant had engaged in the relationship multiple times over a significant duration, and that evidence—specifically video recordings of the intimate encounters made by the complainant herself—pointed toward a consensual arrangement rather than coercion.

The Court held that the case squarely fell within the criteria laid down in Bhajanlal , specifically where the allegations are so "absurd and inherently improbable" that no prudent person could conclude there is sufficient ground for prosecution.

Key Observations

The High Court’s ruling highlighted the dangers of misusing sensitive criminal provisions:

• "This Court has referred to the decision of the Apex Court in State of Haryana v. Bhajan Lal... wherein the Apex Court has laid down the guidelines governing the exercise of inherent powers under Section 482."
• "On referring the above provisions and the facts of the present case, it emerges that this is a case of honey trap and not, in any manner, a case of rape."
• "Keeping the video on, indulging into physical relations... is nothing but consensual relations made by the complainant which was subsequently used to extort the money."
• "In that background, the applicant cannot be sent for the trial for false allegations."

Final Verdict: A Procedural Reset

Finding the proceedings to be an abuse of the court's process, the High Court ordered the immediate quashing of the FIR registered at Dumas Police Station. This decision serves as a stern reminder that while the law provides robust protections against sexual violence, it also possesses the inherent authority to protect citizens against malicious prosecutions intended to extort assets or settle personal vendettas.