This criminal appeal is against the judgment of the High Court of Madhya Pradesh at Gwalior, which dismissed the appellant's criminal revision petition challenging the framing of charges under Sections 376(2)(n) and 506 of the IPC. The prosecutrix alleged that the appellant coerced her into a relationship under threats of exposing her private photographs and later exploited her financially and sexually on the false promise of marriage. The appellant's counsel argued that the relationship was consensual and lacked criminal elements, while the prosecution maintained that there was sufficient material to frame charges. The Supreme Court found inconsistencies in the prosecutrix's statements and lack of substantial evidence, indicating a consensual relationship that later turned sour. Consequently, the Court viewed the continuation of the trial as an abuse of judicial process and set aside the charges against the appellant.

1. Introduction

• Appeal against High Court judgment dismissing Criminal Revision No. 2288 of 2019.
• Charges framed under Sections 376(2)(n) and 506 IPC against the appellant.

2. Prosecution's Case

• FIR lodged by the prosecutrix on 06.09.2018.
• Allegations of coercion, blackmail, and false promise of marriage.

3. FIR and Chargesheet

• FIR registered as Crime No. 401 of 2018.
• Chargesheet filed under Sections 376 and 506 IPC.

4. Application for Discharge

• Appellant's application under Section 227 Cr.P.C. seeking discharge.
• Sessions Judge rejected the application, framing charges against the appellant.

5. Criminal Revision Petition

• Appellant filed a criminal revision petition under Section 397 Cr.P.C.
• High Court dismissed the revision petition.

6. Special Leave Petition

• Appellant preferred Special Leave Petition before the Supreme Court.
• Interim order staying further proceedings and later granting leave.

7. Appellant's Arguments

• Relationship was consensual, and no offence was committed.
• Request to quash the proceedings.

8. Respondent's Arguments

• Prosecution's reliance on the prosecutrix's statements and collected materials.
• Trial court's framing of charges justified based on prima-facie evidence.

9. Examination of Prosecutrix's Statements

• Inconsistencies in statements under Section 161 and 164 Cr.P.C.
• Lack of seizure of crucial evidence (photographs, mobile phone, affidavits, jewellery).

10. Legal Examination

• Definition of rape under Section 375 IPC and consent.
• Examination of Section 90 IPC and the concept of consent under misconception of fact.

11. Conclusion and Decision

• Physical relationship deemed consensual.
• No substantial evidence supporting charges of rape or intimidation.
• Quashing of trial proceedings justified due to lack of evidence and abuse of judicial process.

12. Key Observations

• Consensual nature of the relationship.
• Lack of substantial evidence to support prosecutrix's allegations.
• Case of a consensual relationship turned sour, leading to FIR lodging.

13. Final Decision

• Appeal allowed.
• Orders of the High Court and Sessions Judge set aside.
• Quashing of proceedings in Sessions Trial No. 505 of 2018.