Supreme Court Lays Down Four-Step Test for Quashing Criminal Cases

Supreme Court Lays Down Four-Step Test for Quashing Criminal Cases

On the date of 9 September 2025, the Supreme Court of India in Pradeep Kumar Kesarwani v. Proceedings against a rape case in the State of Uttar Pradesh and Anr. were quashed on the basis of the so-called false promise of marriage. The case was initiated in 2014 over the events that occurred in 2010, however, the Court determined that there were severe shortcomings in the case: a four-year inexplicable delay, indistinct and inconsistent assertions, and the absence of corroborating data. The Court found that it would be an abuse of judicial process to allow the continuance of the trial. And more importantly, it also brought a four-step test to the High Courts in determining petitions under Section 482 CrPC (since replaced by Section 528 BNSS). High Courts should consider: (1) the material upon which they are relying has to be reliable and beyond reproach, (2) that it has to clearly disprove the allegations, (3) that it has to be unrefuted or irrefutable, and (4) that proceeding with trial would not be against justice or would amount to abuse of the process. The purpose of this framework is to strike the right balance between fairness and averting harassment by the use of weak cases.