Defense of the accused cannot be considered or meticulously examined at the stage of framing charges.

The applicant filed a criminal revision under Sections 438 and 442 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023, challenging an order dated 05.02.2026 passed by the Second Additional Sessions Judge, Sarangarh

The trial court had framed charges against the applicant under Section 69 of the Bharatiya Nyaya Sanhita (BNS), 2023, in connection with an FIR registered on 26.09.2025

The prosecution alleged that the applicant induced the complainant into a physical relationship between March and July 2025 by providing a false promise of marriage

The applicant sought discharge, contending that he had filed a prior complaint on 16.09.2025 alleging that the prosecutrix was extorting and threatening him, thereby suggesting false implication

1. Whether the trial court's order framing charges under Section 69 of the BNS was sustainable despite the applicant’s defense of prior complaints against the prosecutrix

2. Whether the court is permitted to evaluate the merits of the accused's defense or conduct a meticulous appreciation of evidence at the stage of framing charges

The court applied Section 69 of the BNS, 2023, which addresses sexual intercourse by deceitful means or on the pretext of a promise to marry

It relied on the principle from State of Rajasthan v. Fatehkaran Mehdu (2017), which establishes that at the framing stage, the court only looks for a "strong suspicion" of the offence, not a final test of guilt

It further applied the ratio from State of M.P. vs. Deepak (2019) and State (NCT of Delhi) vs. Shiv Charan Bansal (2020), stating that the court cannot conduct a "mini-trial" or a roving inquiry into the evidence, but must only evaluate if a prima facie case exists to proceed with the trial

The Court reasoned that at the stage of framing charges, the defense of the accused cannot be considered as it would contravene established criminal jurisprudence

It observed that the trial court is not required to sift through evidence to see if it would lead to a conviction, but only to see if there are grounds for "presuming" the commission of the offence

Upon reviewing the charge sheet and the victim’s written complaint, the Court found that a prima facie case under Section 69 of the BNS was established

Regarding the applicant's defense (the prior extortion complaints), the Court held that such claims must be tested during the trial through examination and cross-examination rather than being accepted as "gospel truth" at the preliminary stage

The High Court dismissed the revision petition at the admission stage, affirming the framing of charges under Section 69 of the BNS