To,
Honorable Justice Sh. M Nagaprasanna,
High Court of Karnataka


Respected Sir,

My name is Deepika Narayan Bhardwaj. I am an independent journalist, documentary filmmaker and a social activist. I am Director of Ekam Nyaay Foundation, a non-governmental organization that provides support to individuals affected by false accusations, wrongful convictions, and other human rights violations, offering legal aid, emotional support, counseling and bring cases to light where men are at the receiving end of abuse. For last 12 years I have advocated for legislative changes to address gender-biased laws in India and misuse of gender specific laws. My documentary films showcasing plight of victims of false accusations of rape, dowry laws have been showcased at Judicial Academies, Law Colleges and Courts as well.
Sir, I am writing to you today to seek stern action against a woman who has abused laws with impunity for last one decade.

A case pertaining to this woman whose name is Deepika YG was brought on board of your Hon’ble Court where it has been recorded that she is abusing the process of law. This lady, Deepika Y. G, has filed a total of 10 FIRs. She has filed 5 FIRs under section 376 for rape claiming false promise of marriage in all, 2 FIRs under section 498-A, and the rest cases under section 354 and other sections related to criminal intimidation, hurt, cheating, conspiracy etc as observed by you during court hearing on 28.8.24. Several complaints and cases pertaining to harassment, blackmail, extortion and criminal intimidation have been filed against her as well.

Sir, I am in touch with some of the victims against whom this lady has filed false cases. Their experiences are very disturbing and some of them have been running around courts for years to fight for their innocence. I particularly remember meeting a woman who was pregnant when Deepika implicated her along with a man in a rape case and she was arrested. Several families have been harassed, tortured and threatened by this lady and many complaints have also been made but unfortunately, Bangalore Police has not taken strong action against this woman and she has gone on filing rape cases one after the other since years. I am told she is brazen in demanding money after filing
these cases and proudly tells people that all that she needs to implicate them in a rape case is to go to the police station and lodge a complaint. It is perhaps the first time that this case has been taken a very serious look at by your honorable court and I sincerely hope that this puts an end to the endless cases this woman has filed against numerous people.

I wish to bring to your notice sir that the case of Deepika YG is not one off instance. There is rampant misuse of rape laws particularly the allegations of rape on false promise of marriage. These allegations are being used as a weapon by unscrupulous women to extort money, force marriage and exact revenge from their partner in case a relationship turns sour. Such frivolous cases have not only clogged the judicial system but also shot up the rape statistics by an enormous number.

I would like to bring to your cognizance some cases in which I have personally assisted victims. In 2021, I wrote to DGP Haryana about a woman who had filed 9 rape cases on 9 men within one year in one city – Gurgaon. In 2022, I met the Commissioner of Police Jabalpur to file a complaint against a woman who was married but had filed 4 rape cases claiming false promise of marriage and 6 rape cases in total. In 2023, I wrote to DGP Rajasthan about a woman who had filed 14 cases of rape, molestation in a span of 8 years in Jaipur, Gurgaon, MP. Since I brought these cases to light, victims
from all over India have written to me about women who have filed multiple rape, molestation cases on innocent citizens with the police continuing to register these cases without any due diligence. In most of these cases, police took no action despite repeated complaints against the same woman.

Here are some cases that we have documented from across India where one woman has lodged multiple cases of Rape. In some cases, they have gone to various states and lodged the cases.

As a grassroots organization, we have been working tirelessly to expose these instances of misuse. But it is extremely important for the Judiciary to take stern action against women who have made a mockery of a heinous crime like Rape.

Taking cognizance of one such matter, in 2021, Hon'ble Justice Arvind Singh Sangwan of the High Court of Punjab and Haryana in the case of Sejal Sharma vs State Of Haryana passed stern remarks against a honey trap gang that had filed numerous rape cases against several people in order to
commit extortion. Hon’ble Court issued a direction to the Director General of Police, Haryana to communicate to all the Superintendents of Police in the State of Haryana that in case, in future, any FIR is registered at the instance of the false case filer Sejal Sharma, and the other co-accused, leveling
allegations of rape or molestation against any person, no FIR to be registered, unless the matter is thoroughly inquired into by the police. Court also directed that at all District Headquarters, a record be maintained by SP Office concerned regarding such or similar complainants, who have registered
more than one complaint of allegation of rape or where complaints are made by victims of Honey Trap, so as to keep a check and to protect innocent citizens.

Taking cognizance in another such matter, in November 2023 Hon’ble Justice Sh. Vishal Dhagat of the High Court of Madhya Pradesh - Jabalpur passed an order to quash a criminal proceeding of Rape on the False Pretext of Marriage as the prosecutrix was already married and had filed multiple FIRs against various persons using the same modus-operandi of misusing gender-specific laws to harass innocent men. In this matter the Hon’ble Judge passed directions to the concerned Police Station that information regarding the complainant/ prosecutrix be uploaded in interoperable Criminal Justice
System so that Police Stations shall have information in advance about the habit of the prosecutrix in laying honey-trap and falsely implicating innocent persons in false cases.

It is disturbing to note that at present there is no effective mechanism anywhere across the country where police can find how many cases have been registered by one woman against various persons particularly in a heinous crime like Rape. Several such cases that are happening across the country clearly demand a mechanism to be put in place so that innocent citizens can be protected from such chronic abusers of law. Given the situation we are seeing in the country today where women are being
subjected violent and brutal rapes, such false cases need to be weeded out and such false accusers given harshest punishment so that the system doesn’t get clogged and actual victims get swift justice.

Sir, we have come across some noteworthy judgments by you in the recent past and have a strong purpose to write this Open-Letter to you on behalf of all the innocent citizens and their families who are facing the brunt of misuse of women-centric laws and living in extreme situations of despair, helplessness and hopelessness. Rape is the most heinous crime. Judiciary has gone at length to describe the life long traumas of rape victims. They deserve empathy, care, swift justice and support of society. Equally, victims of false rape accusations also undergo unexplained ordeals as on mere accusation, people lose their jobs, face incarceration and have their image and respect totally tarnished in the society. Even after they are proven innocent, there is hardly any sense of justice, as the woman who foisted the case faces no repercussions.

Every Rapist deserves to be given the harshest punishment under law. For a fair society, every woman who files a false rape case deserves harshest punishment too. Ideals of Equality cannot be met solely by giving justice to women while leaving men in lurch.

Therefore, we humbly request your esteemed court to take cognizance of misuse of rape laws by women like Deepika YG and issue orders that can set precedent for every such case.

We request your honorable court to kindly consider passing the following directives to the Director General of Police of the State of Karnataka while disposing off this case:

1. Pre-Arrest Investigation: In rape cases where allegations of promise of marriage are made, the Director General of Police should be directed to mandate all the police stations to conduct a thorough pre-arrest investigation to establish the veracity of the complaint. This will help prevent unnecessary arrests and protect innocent individuals from undue harm.

2. Database of Serial complainants: A database should be maintained to track women who have a history of filing similar cases against multiple men across the State. This will assist law enforcement agencies in identifying potential patterns of misuse and taking appropriate action.

We are confident that your intervention will go a long way in curbing the misuse of gender-biased laws and ensuring that these laws serve their intended purpose of protecting the rights and dignity of women while also safeguarding the interests of innocent individuals.

Thank you for your time and consideration.

Sincerely,


Deepika Narayan Bhardwaj
Founder Director
Ekam Nyaay Foundation