Interference with criminal proceedings denied; disputed facts require trial, not inherent jurisdiction.

The petitioner, Toman Das Sahu, sought to quash a charge-sheet (No. 573/25, dated 13.07.2025), FIR (No. 473/25, dated 25.04.2025) registered under Section 376(2)(n) of the IPC, an order taking cognizance (dated 08.12.2025), and criminal proceedings (Sessions Trial No. 376/25) pending before the Court of Additional Sessions Judge, FTC, Durg.

The petitioner also sought to quash charges framed under Section 376(2)(n) of the IPC (vide order dated 13.01.2026).

The victim, aged 29, alleged she met the petitioner in 2020, exchanged numbers, and subsequently cohabited at various places.

She claimed the petitioner established physical relations on the false pretext of marriage, concealing his existing marriage.

An FIR was registered, and the petitioner was granted anticipatory bail.

After investigation, a charge-sheet was filed.

Subsequent to the charge-sheet, the victim filed an application under Section 9 of the Hindu Marriage Act, averring she was engaged to the petitioner on 21.12.2021 and married him on 28.12.2021 according to Hindu rites, residing together as husband and wife.

The prosecution noted that the victim alleged inducement for physical relations but also asserted a subsequent marital relationship and cohabitation.

The petitioner contended that the victim’s contradictory stands—alleging false promise of marriage for physical relations in one proceeding and a valid marital relationship in another—rendered the rape allegations false and baseless.

The State counsel asserted that the victim’s complaint detailed consistent allegations of physical relations under false promise of marriage, supported by investigation including medical examination, witness statements, and hotel records.

1. Whether the allegations of rape against the petitioner are false and baseless due to contradictory statements made by the victim in different proceedings.

2. Whether the continuation of criminal proceedings against the petitioner amounts to an abuse of the process of law.

3. Whether, at this stage, it can be concluded that the allegations in the FIR and charge-sheet do not disclose a cognizable offense.

The court's inherent jurisdiction allows interference only when allegations, even if taken at face value, do not disclose a cognizable offense or when proceedings constitute an abuse of process.

Disputed questions of fact, appreciation of evidence, and credibility assessment are matters to be adjudicated during trial.

The court heard arguments from both counsels and reviewed the available material.

It found that the contentions raised by the petitioner involved disputed questions of fact, requiring appreciation of evidence and examination of the credibility of rival versions.

These complex factual determinations could only be appropriately adjudicated during the course of a full trial.

At the current stage, the court could not definitively state that the allegations in the FIR and the material in the charge-sheet did not disclose the commission of any cognizable offense.

Furthermore, the court determined that the continuation of the proceedings did not amount to an abuse of the process of law.

Therefore, the court concluded that no case was made out for interference in the exercise of its inherent jurisdiction, considering the nature and gravity of the allegations and the stage of the trial.

The court held that no case for interference in its inherent jurisdiction was made out, as the contentions raised involved disputed questions of fact, appreciation of evidence, and examination of credibility, which are matters for trial.

It was explicitly held that it could not be said, at this stage, that the allegations in the FIR and charge-sheet did not disclose a cognizable offense or that the continuation of proceedings would amount to an abuse of the process of law.