Supreme Court Sets Precedent: FIR Quashed in Controversial Rape Allegation Case.


In a significant ruling concerning Lalu Yadav v/s The State of Uttar Pradesh & Others, the Supreme Court has set aside the order of the Allahabad High Court, which had previously dismissed a plea to quash an FIR related to allegations of rape and abortion. The case highlights intricate issues surrounding consent, the timing of allegations, and the nature of relationships.

Case Background:

The appeal stems from an order dated July 26, 2018, concerning an FIR registered on February 21, 2018, against Lalu Yadav under Sections 376 and 313 of the Indian Penal Code (IPC) at Police Station Nandganj in Ghazipur District, Uttar Pradesh. The FIR was filed by a woman claiming that Yadav had established a physical relationship with her under false pretenses, promising to marry her while she was still a high school student.
The complainant alleged that their relationship led to multiple incidents of physical intimacy, resulting in two pregnancies, both of which she claimed were terminated through coercive means. The FIR further stated that Yadav refused to marry her after obtaining a job in the army.

 

 

Legal Proceedings:

The Supreme Court noted that the High Court had previously ruled against quashing the FIR, citing the significant time lapse of five years from the alleged incidents to the registration of the complaint. However, this ruling was challenged as the investigation progressed, revealing that the charge under Section 313 (related to abortion) had been omitted due to a lack of evidence.
In the review of the FIR and the circumstances surrounding the case, the Supreme Court emphasized the importance of discerning whether the relationship was consensual. The court referenced previous rulings that highlighted the need to evaluate allegations of rape, particularly those involving claims of false promises of marriage, against the backdrop of the nature of the relationship.

Key Findings:

Consent and Misconception: The FIR presented conflicting statements regarding consent. The complainant claimed Yadav had established a relationship "without consent," yet also described living together as husband and wife.
Delay in Filing the FIR: The five-year delay in bringing forth the complaint raised questions about the credibility of the allegations.
Nature of Relationship: The Supreme Court found that the relationship, characterized by mutual consent and acknowledgment of living together, suggested that the allegations did not meet the criteria for rape under IPC Section 375.
Omission of Charges: The investigation concluded that there was insufficient evidence to support the abortion charge under Section 313, effectively undermining the prosecution's case.

Conclusion:

Ultimately, the Supreme Court held that there was no prima facie case for proceeding with the allegations of rape against Yadav. It concluded that the High Court should have exercised its inherent powers to prevent an abuse of the judicial process.
As a result, the Supreme Court quashed FIR No. 28/2018 and all related proceedings. This ruling not only underscores the complexities involved in cases of sexual violence but also serves as a reminder of the importance of thorough investigations and the careful consideration of consent in intimate relationships.
The decision is likely to have implications for similar cases, reinforcing the need for clarity and caution in the handling of allegations of this nature.

  Code of Criminal Procedure, 1973    Indian Penal Code, 1860