In State v. Rangoli Gautam, Lucknow Court convicted Rangoli Gautam u/s 182, 193, and 211 IPC, sentencing her to 7 years of imprisonment and imposing a fine of ₹52,000 for fabricating a false rape and SC/ST Act case against Kaushal Kumar Aggarwal. Court emphasised that false prosecutions not only destroy innocent lives but also weaken the credibility of special legislations.

Court observed, “It is being increasingly noticed that false complaints of molestation, gang rape, or SC/ST Act offences are being hurriedly registered at police stations. Under Sections 18 and 18A of the SC/ST Act, provisions exist whereby upon registration of an FIR and till filing of the charge-sheet, compensation ranging from ₹1 lakh up to ₹8.25 lakh is made payable to the complainant.”

The case arose from an FIR lodged in Lucknow, in which Rangoli accused Kaushal, manager and partner of Hotel Sara Grand, of calling her to his hotel and intoxicating her by lacing her tea, raping her, threatening her, and humiliating her on caste grounds on 08.08.2022.

However, immigration records showed that Kaushal had left for Canada on 02.08.2022 and returned only on 15.09.2022, proving that he was not present in India on the alleged date.

Further investigation revealed that on 08.08.2022, Rangoli herself booked a room in Hotel Sara Grand at 3:25 PM, paying ₹1,200 in her own name. Hotel registers confirmed the booking. CCTV footage showed that Rangoli checked in alone with her child, and no man ever entered the room. After leaving the hotel, she went to the police station and filed the FIR.

Rangoli conspired with a female advocate to fabricate rape charges before lodging the FIR. She underwent a medical examination, which found no evidence of intoxication or sexual assault. Due to absence of evidence, a Closure Report was filed on 24.09.2022.

A chargesheet was filed against Rangoli u/s 182 and 195 IPC, for giving false evidence and misusing investigative agencies. The counsel for the accused argued that Rangoli be prosecuted u/s 182, 193, and 211 IPC, highlighting that she was a habitual litigant who had previously filed an FIR u/s 504, 506, and 352 IPC, showing a pattern of misuse of criminal law.

Court held, “When legal safeguards are exploited for personal or financial gain, it dilutes their effectiveness and erodes public trust in the justice system… such misuse must be dealt with sternly.”
Accordingly, Rangoli Gautam was convicted under Sections 182, 193, and 211 IPC.

The Court further directed that a copy of the judgment be sent to the Police Commissioner, Lucknow, with clear directions that in all cases of rape, gang rape, and POCSO cases, it is mandatory to verify whether the complainant or her family members have previously filed similar FIRs against others. This information must be documented in the case diary and brought to the court’s notice. The use of AI tools may assist in gathering such information.

Furthermore, Court emphasised that if any relief amount or government compensation has been granted in a false case, immediate steps must be taken to recover it.

Court also underlined that the filing of a chargesheet constitutes only a prima facie case and does not establish guilt. The legislature never intended that taxpayers’ hard-earned money should be misused by granting compensation to mischievous persons filing false FIRs under the SC/ST Act or similar provisions. If it is found that compensation was obtained through a false complaint, it must be treated as misuse of public funds, and strict recovery should be ensured.