Anticipatory bail was denied amid serious allegations of sexual relations induced by a promise to marry.

The applicant sought anticipatory bail under Section 482 of the Bharatiya Nagarik Suraksha Sanhita, 2023, in connection with Crime No. 76/2026 registered at Police Station Mahila Thana, District Waidhan, for an offence under Section 69 of the Bharatiya Nyaya Sanhita, 2023.

The prosecution alleged that the applicant and the victim, both majors, were expected to marry and consequently met each other.

The applicant allegedly established physical relations with the victim in November 2025 and again on 27 February 2026 at J.D. Palace, and subsequently took her to Satna on 14 June 2026, where he stated that he would not marry her.

The applicant claimed that the marriage was abandoned because his family allegedly objected to the victim’s mental-health condition, and that the victim thereafter demanded ₹4,00,000 and land while threatening to implicate him falsely.

He relied on a complaint allegedly lodged by him in support of his plea of false implication.

The State opposed anticipatory bail, relying on the FIR and the victim’s statement recorded under Section 183 of the BNSS, asserting that the applicant had promised marriage and thereafter refused to marry the victim.

1. Whether the applicant was entitled to anticipatory bail under Section 482 of the Bharatiya Nagarik Suraksha Sanhita, 2023, in relation to the offence registered under Section 69 of the BNS.

2. Whether the allegations that the applicant obtained physical relations on the promise of marriage, subsequently refused to marry the victim, and thereby committed a serious offence justified protection from arrest.

The Court applied Section 482 of the Bharatiya Nagarik Suraksha Sanhita, 2023, governing directions for grant of anticipatory bail.

It relied on State of M.P. v. Pradeep Sharma, (2014) 2 SCC 171, which explains that anticipatory bail is an extraordinary remedy to be exercised in exceptional cases, particularly where the accusation appears false or where there are reasonable grounds to believe that the applicant is unlikely to misuse his liberty.

The factors relevant to anticipatory bail include the nature and gravity of the accusation, the applicant’s antecedents, the possibility of fleeing from justice, and whether the accusation was made with the object of humiliating or injuring the applicant.

The Court considered the applicant’s defence that both parties were majors, that their marriage had been fixed, and that the FIR was a consequence of the victim’s alleged monetary demands and threat of false implication.

However, the Court also considered the FIR and the victim’s statement under Section 183 of the BNSS, which alleged that the applicant had promised marriage, established physical relations with the victim, and later refused to marry her.

In light of the seriousness of these allegations, the Court held that the case did not warrant the exceptional protection of anticipatory bail.

The Court therefore declined to accept the applicant’s claim of false implication at the pre-arrest stage.

No anticipatory bail relief was granted in Crime No. 76/2026 registered at Police Station Mahila Thana, District Waidhan.