Surendra Khawse v. State of Madhya Pradesh 2025 INSC 1143 - S.482 CrPC - Ulterior Motives

Bharatiya Nagarik Suraksha Sanhita 2023 - Section 528 : Code of Criminal Procedure 1973 - Section 482 - Quashing of criminal proceedings is when the same is initiated in pursuance of ulterior motives. [Context: The appellant was accused of rape by a colleague after their friendship and physical relationship soured. The complainant filed an FIR months after the alleged incident, and only after facing disciplinary action at work following complaints by the appellant- SC held: The fact that the subject FIR was only lodged after the issuance of show-cause notice, which obviously has large real-world implications insofar as the complainant is concerned, leaves open a gaping possibility that the same was lodged as an afterthought and was a vehicle for vengeance for the impending consequences]

Case Info


Case Name and Neutral Citation

  • Case Name: Surendra Khawse v. State of Madhya Pradesh & Anr.
  • Neutral Citation: 2025 INSC 1143

Coram (Judges)

  • Justice Sanjay Karol
  • Justice Nongmeikapam Kotiswar Singh

Judgment Date

  • Date: 22 September 2025

Caselaws and Citations Referred

  1. State of Haryana v. Bhajan LalCitation: 1992 Supp (1) 335
  2. M. Srikanth v. State of TelanganaCitation: (2019) 10 SCC 373
  3. Balaji Traders v. State of U.P.Citation: 2025 SCC OnLine SC 1314
  4. Mohd. Wajid v. State of U.P.Citation: (2023) 20 SCC 219

Statutes/Laws Referred

  • Bhartiya Nagrik Suraksha Sanhita, 2023 (BNSS 2023)
    • Section 528: Saving of inherent powers of High Court
  • Indian Penal Code (IPC)
    • Section 376
    • Section 376(2)(n)
  • Code of Criminal Procedure, 1973 (Cr.PC)
    • Section 155
    • Section 482