In Pradeep Kumar Kesarwani v. The State of Uttar
Pradesh & Anr.,
MANU/SCOR/68068/2025 ("Pradeep
Kesarwani's case"), the Supreme Court
reiterated the judiciary's duty to guard against the misuse of
criminal process, particularly in sensitive cases, while
reiterating a four-pronged test which must be followed to determine
which criminal cases ought to be quashed.
Setting aside the order dated 12 September 2019
("Impugned Order") passed by the
Hon'ble High Court of Judicature at Allahabad
("Allahabad High Court"), the Apex Court
underscored that vague, uncorroborated, and belated allegations
cannot be used to harass the accused (the case pertained to
allegations of rape basis false promise to marry). Most
importantly, the Apex Court reiterated the importance of the
'four step test' as laid down in Rajiv
Thapar & Ors v. Madan Lal Kapoor, (2013)
3 SCC 330 (Rajiv Thapar's
case), to determine the cases in which a High Court
should exercise its powers of quashing a
