Supreme Court on Quashing of FIR: Allegations Must Be Scrutinized in Light of Entire Record.

The Supreme Court reiterated that while exercising powers under Section 482 CrPC or Article 226 of the Constitution to quash criminal proceedings, the High Court must carefully assess whether the allegations, taken at face value, disclose a prima facie case. The Court observed that the High Court erred in quashing the FIR solely on the ground of alleged consensual relationship between the parties when the complaint and evidence suggested otherwise.

1. The appellant, Muskan, filed an FIR against respondent Ishaan Khan (Sataniya) alleging offences under Sections 376 and 506 of the IPC, claiming that the respondent had physical relations with her on the false promise of marriage.
2. The respondent moved the High Court seeking quashing of the FIR under Section 482 CrPC, asserting that the relationship was consensual and that no offence was made out.
3. The High Court accepted the contention and quashed the FIR, observing that both parties were adults and the element of “false promise” was not substantiated.
4. Aggrieved, the appellant approached the Supreme Court.

1. The Supreme Court held that the High Court exceeded its jurisdiction by making factual determinations at the quashing stage, where only a prima facie examination is permissible.
2. It emphasized that the veracity of the allegations, consent, and intention behind the alleged promise are matters for trial, not for summary dismissal under Section 482 CrPC.
3. The Court further observed that the nature of consent under coercive or deceptive circumstances must be judicially examined based on evidence.
4. The High Court’s interference at the threshold, in a matter involving serious allegations of sexual assault, was held to be inappropriate.

1. The Supreme Court set aside the High Court’s order quashing the FIR.
2. It restored the criminal proceedings, directing that the trial be conducted in accordance with law and without being influenced by the High Court’s observations.

1. Section 376, Indian Penal Code, 1860 – Punishment for rape.
2. Section 506, Indian Penal Code, 1860 – Punishment for criminal intimidation.
3. Section 482, Code of Criminal Procedure, 1973 – Inherent powers of the High Court.
4. Article 226, Constitution of India – Writ jurisdiction of the High Courts.

Citation: 2025 INSC 1287

Case: Muskan v. Ishaan Khan (Sataniya) & Others

Court: Supreme Court of India

Coram: Justice Prashant Kumar Mishra

Date of Decision: 6 November 2025

Criminal Appeal No.: 4752 of 2025 (Arising out of SLP (Crl.) No. 1531 of 2025)