A division bench of Supreme Court held as follows in a false rape case,
From Para 13,
13. Having heard the learned counsel appearing for the parties and having gone through the materials on record, we are of the view that the Additional Chief Judicial Magistrate committed an error in passing the summoning order. The High Court too overlooked the relevant aspects of the matter while rejecting the Section 482 application. It is very apparent on a plain reading of the complaint, more particularly, considering the nature of the allegations that the same doesn’t inspire any confidence. There is no good explanation offered, why it took four years for the respondent no.2 to file a complaint.
From Para 20,
20. The following steps should ordinarily determine the veracity of a prayer for quashing, raised by an accused by invoking the power vested in the High Court under Section 482 of the Cr.P.C.:-
(i)Step one, whether the material relied upon by the accused is sound, reasonable, and indubitable, i.e., the materials is of sterling and impeccable quality?
(ii) Step two, whether the material relied upon by the accused, would rule out the assertions contained in the charges levelled against the accused, i.e., the material is sufficient to reject and overrule the factual assertions contained in the complaint, i.e., the material is such, as would persuade a reasonable person to dismiss and condemn the factual basis of the accusations as false.
(iii) Step three, whether the material relied upon by the accused, has not been refuted by the prosecution/complainant; and/or the material is such, that it cannot be justifiably refuted by the prosecution/complainant?
(iv) Step four, whether proceeding with the trial would result in an abuse of process of the court, and would not serve the ends of justice?
If the answer to all the steps is in the affirmative, judicial conscience of the High Court should persuade it to quash such criminal – proceedings, in exercise of power vested in it under Section 482 of the Cr.P.C. Such exercise of power, besides doing justice to the accused, would save precious court time, which would otherwise be wasted in holding such a trial (as well as, proceedings arising therefrom) specially when, it is clear that the same would not conclude in the conviction of the accused. [(See: Rajiv Thapar & Ors. v. Madan Lal Kapoor (Criminal Appeal No. 174 of 2013)]
Citations: [2025 LiveLaw (SC) 880]
Other Sources:
https://www.livelaw.in/sc-judgments/2025-livelaw-sc-880-pradeep-kumar-kesarwani-versus-the-state-of-uttar-pradesh-anr-303321
https://www.barandbench.com/news/litigation/supreme-court-quashes-false-rape-case-lays-down-four-step-test-to-quash-frivolous-criminal-complaints
https://lawbeat.in/supreme-court-judgments/sc-quashes-rape-complaint-filed-after-4-years-explains-when-promise-of-marriage-is-not-rape-1518116
https://www.theedulaw.in/content/judgements/235/Court-laid-down-a-structured-four-step-test-to-evaluate-applications-for-quashing-criminal-proceedings.-
https://www.courtkutchehry.com/pages/blog/supreme-court-unveils-four-step-test-to-quash-frivolous-criminal-cases/
https://thelawgist.org/supreme-court-four-step-test-for-quashing-petitions-2/
PRADEEP KUMAR KESARWANI VERSUS THE STATE OF UTTAR PRADESH (Supreme Court)
Index of Quash judgments is here.