Sexual Exploitation on False Promise of Marriage Cannot be Quashed Based on Private Settlement Alone.

The petitioner sought to quash Final Report No. 02/2026, FIR No. 149/2025, and the subsequent cognizance order dated 12.01.2026.

The complainant (Respondent No. 2) alleged that the petitioner, her employer, sexually exploited her between April 2022 and September 2025 under a false promise of marriage and threats of death/defamation.

The petitioner contended the prosecution was a "counterblast" to a physical assault complaint he filed against the victim on 30.10.2025.

During the pendency of this petition, Respondent No. 2 filed an affidavit stating she no longer wished to pursue the criminal proceedings due to an amicable settlement.

Whether the criminal proceedings under Sections 69 and 351(2) of the Bhartiya Nyaya Sanhita (BNS), 2023, should be quashed on the grounds of lack of prima facie material and alleged personal animosity.

Whether the high court should exercise its inherent jurisdiction to quash the proceedings based on a settlement affidavit filed by the victim in a case involving allegations of sexual exploitation.

The Court applied Sections 69 (sexual intercourse on false promise of marriage) and 351(2) (criminal intimidation) of the Bhartiya Nyaya Sanhita, 2023.

Regarding the exercise of inherent powers to quash proceedings, the Court relied on the landmark precedent of *State of Haryana v. Bhajan Lal*, which mandates that inherent jurisdiction should be exercised sparingly and only in the "rarest of rare cases" where allegations, taken at face value, do not disclose an offence.

Furthermore, the court applied the principle that serious offences involving sexual exploitation possess a "significant societal element" and are not purely private disputes that can be terminated solely by a settlement between parties.

The Court observed that the Investigative Agency had conducted a comprehensive probe, including recording statements, preparing site maps, and seizing the vehicle used in the alleged offence.

It reasoned that while the petitioner claimed the relationship was consensual and the FIR was delayed, these constitute "disputed questions of fact" that must be tested during a full-fledged trial.

The Court rejected the argument for quashing based on the victim’s settlement affidavit, noting that sexual exploitation allegations are not private in nature; therefore, once a charge sheet is filed and cognizance is taken based on material evidence, the matter cannot be dismissed simply because the complainant had a change of heart.

The Court answered that inherent jurisdiction cannot be used to bypass a trial when specific assertions of inducement and threats are present.

While the petition was dismissed, the Court clarified that its observations would not prejudice the parties during the trial.