Court Finds Allegations of Rape, Cheating, and Breach of Trust Groundless; Dispute Deemed Civil and Financial
In a significant judgment delivered by the Allahabad High Court on July 6, 2026, Justice Santosh Rai quashed the charges against Saurabh Pal Singh, who faced serious allegations including rape, cheating, criminal breach of trust, and offenses under the SC/ST Act. The court found that the material on record did not provide sufficient grounds to presume that the appellant committed the alleged offenses.
The case, originating from a First Information Report (FIR) filed in 2020 by Manju Saroj, a Scheduled Caste woman pursuing her Ph.D., accused Singh of establishing a physical relationship with her under a false promise of marriage. She further alleged that Singh misappropriated her scholarship money, ATM card, jewelry, and Rs.15,00,000 on the pretext of starting a restaurant, later refusing to marry her.
The High Court meticulously reviewed the evidence presented, including the FIR and statements recorded under Sections 161 and 164 Cr.P.C. It concluded that the allegations lacked prima facie evidence necessary for framing charges, noting that the dispute was primarily civil and financial in nature. The judgment emphasized that the continuation of criminal proceedings would amount to an abuse of the process of law.
In its analysis, the court reiterated principles governing the discharge under Section 227 Cr.P.C. and emphasized that the court must apply its judicial mind to the material on record. The judgment cited precedents from the Supreme Court, underscoring that a mere promise of marriage that turns false due to subsequent circumstances does not constitute rape under Section 376 IPC unless it was false from the inception.
Furthermore, the court highlighted that the provisions of the SC/ST Act could not be invoked merely because the victim belonged to a Scheduled Caste. It must be demonstrated that the offense was committed on the ground of caste identity, a requirement not met by the evidence presented.
Ultimately, the court found no material connecting the alleged acts to the informant’s caste identity or indicating a dishonest intention at the inception of the financial transactions, which were deemed voluntary. Consequently, the court discharged Saurabh Pal Singh from the charges, setting aside previous orders by the Special Judge (SC/ST Act), Prayagraj.
The judgment sets a precedent in distinguishing civil disputes from criminal offenses and reinforces the legal principles preventing misuse of criminal law for civil or financial disputes. The High Court's decision serves as a reminder of the judiciary's role in safeguarding individuals from groundless charges and ensuring justice is served based on substantive evidence.
Bottom line:-
The court held that the material on record, even if accepted at face value, did not disclose sufficient grounds to presume the appellant committed the offences alleged, including rape based on a false promise of marriage, cheating, criminal breach of trust, and offenses under the SC/ST Act. The dispute was predominantly civil and financial in nature, and the allegations lacked prima facie evidence necessary for framing charges.
Statutory provision(s): Sections 227, 376, 420, 406, 504, 506 IPC, Section 3(2)(v) SC/ST Act, Sections 161, 164 Cr.P.C.
Saurabh Pal Singh v. State of U.P., (Allahabad) : Law Finder Doc id # 2939746
