Delhi High Court Quashes Rape FIR Citing Implausible Allegations and Abuse of Process

New Delhi: In a significant ruling, the Delhi High Court has quashed an FIR for rape based on the false pretext of marriage, emphasizing that the continuation of proceedings riddled with "flagrant inconsistencies" and "bereft of any corroborating evidence" would amount to a miscarriage of justice. Justice Amit Mahajan, invoking the court's inherent powers, set aside the FIR lodged against petitioner Parag Prakash Rudrangi.

Case Background

The case originated from FIR No. 460/2018, registered at Police Station Fatehpur Beri under Sections 376 (Rape) and 328 (Causing hurt by means of poison, etc.) of the Indian Penal Code ( IPC ). The complainant (Respondent No. 2) alleged that she met the petitioner in May 2018 and he subsequently established a physical relationship with her on the promise of marriage.

The allegations included an initial incident of rape after being made to drink a spiked cold drink, followed by a consensual relationship lasting over five months, during which the petitioner allegedly lived with her and extorted money. A chargesheet was filed, and an offence under Section 377 (Unnatural offences) was later added. The petitioner, aggrieved by the proceedings, approached the High Court seeking to quash the FIR.

Arguments from Both Sides

Petitioner's Counsel Argued: - The FIR was a "honey trap" with a mala fide motive, aimed at extorting money. - The petitioner was already married with two children, a fact known to the complainant, making a promise to marry her impossible. - The complainant had a history of lodging similar rape cases that resulted in acquittals and had herself admitted to taking money for her company. - The consensual nature of the prolonged relationship negated the premise of rape on a false promise.

Complainant's Counsel Argued: - The FIR and chargesheet disclosed cognizable offences supported by the complainant's statements. - The petitioner's claims about the complainant's marital status and past cases were misleading. - Whether the relationship was consensual or based on coercion was a matter of trial and could not be decided at this stage. - Questioning the complainant's character was irrelevant, and quashing the case would undermine the victim's right to justice.

Court's Analysis and Legal Principles Applied

Justice Mahajan underscored that while the power to quash criminal proceedings, especially after a chargesheet, must be exercised sparingly, the court cannot ignore cases that are manifestly frivolous or instituted with ulterior motives. The court referenced the landmark judgment in State of Haryana v. Bhajan Lal , which permits quashing where proceedings are "manifestly attended with mala fide" or instituted to wreak vengeance.

The judgment noted the court's responsibility to balance equities and prevent the "weaponizing of law to wreak vengeance after souring of relationships."

The court observed several critical points that weakened the prosecution's case:

> "This Court cannot be blind to the fact that with the passage of time, there has been an increasing tendency of weaponizing law to wreak vengeance after souring of relationships, which has a chilling effect on genuine survivors."

Key inconsistencies highlighted by the court included: - Discrepancies in Timelines: The complainant gave conflicting dates for the first alleged incident (June 2018 in her statement, March 2018 in the chargesheet). - Lack of Corroboration: No independent evidence was found to support the allegation of being drugged in a crowded club. Similarly, allegations of unnatural sex leading to infections were not supported by any medical evidence, despite claims of visiting "various" hospitals. - Implausibility of Allegations: The court found it improbable that the complainant, who claimed to have a good relationship with the petitioner's family, would remain unaware of his marital status and children over a five-month period of cohabitation.

The court stated: > "Having found that the versions of Respondent No.2 are riddled with flagrant inconsistencies that go to root of the matter and that the allegations are bereft of material particulars, which are further rendered brittle due to absence of any cogent corroborating evidence... the present case is not one where the totality of the circumstances give rise to grave suspicion against the accused petitioner for framing of charges."

Final Verdict and Implications

The High Court concluded that subjecting the petitioner to the "tribulations of trial" after half a decade, based on unconvincing allegations lacking corroboration, would be an abuse of the legal process. It held that the circumstances did not justify framing charges against the accused.

Consequently, FIR No. 460/2018 and all subsequent proceedings arising from it were quashed. The ruling reaffirms the judiciary's role in safeguarding individuals from malicious prosecution while carefully distinguishing genuine cases from those initiated due to soured relationships.