Rajkumar v. State of Karnataka
In the Supreme Court of India
SLP (Crl) 6279/2023
Before Justice Aniruddha Bose and Justice Sanjay Kumar
Decided on March 05, 2024

Relevancy of the case: Quashing of FIR in a case involving allegations of rape and recording of the act after the end of a consensual relationship

Statutes and Provisions Involved

• The Information Technology Act, 2000 (Section 66E, 67, 67A)
• The Indian Penal Code, 1860 (Section 186, 342, 354, 366, 376, 312, 201, 420, 506, 509)
• The Code of Criminal Procedure, 1973 (Section 482)

Relevant Facts of the Case

• The petitioner was in a relationship with a woman, with whom the relationship soured over time. This led to the woman filing an FIR.
• The petitioner first approached the High Court of Karnataka. However, the High Court dismissed his plea.
• The petitioner approached the Supreme Court of India to quash the FIR filed against him.

Prominent Arguments by the Advocates

• The petitioner’s counsel submitted that the allegations by Miss X were mere counterblasts to the petitioner’s complaint of blackmailing/extortion against her. The counsel also relied on Shambhu Kharwar v. State of Uttar Pradesh, where the court held that a consensual relationship cannot give rise to the offence of rape.

Opinion of the Bench

• The facts made it impossible to conclude that the FIR contained no offences, which contradicts the judgment in State of Haryana v. Bhajan Lal. The allegations were not plausible enough to justify the FIR’s quashing.

Final Decision

• The court declined to interfere with the impugned order, dismissing the petitioner’s plea to invalidate the FIR.