The Supreme Court questioned the Maharashtra government over issuing a Blue Corner Notice in a rape case based on an alleged false promise of marriage, while granting anticipatory bail to an NRI accused and staying coercive measures against him.
Thank you for reading this post, don't forget to subscribe!NEW DELHI: The Supreme Court granted anticipatory bail to an NRI IT professional accused of rape on the false promise of marriage by a Mumbai-based advocate who had earlier guided him in his divorce proceedings. While granting relief, the apex court sharply questioned the Maharashtra government on the issuance of a Blue Corner Notice in a case of this nature, observing that such extreme measures are often not taken even against serious criminals.
A bench comprising Justice B.V. Nagarathna and Justice Ujjal Bhuyan allowed the criminal appeal filed by Praveen Manik Kadam, setting aside the Bombay High Court’s order dated October 15, 2025, which had rejected his plea for anticipatory bail.
Background of the Case
The case arose from FIR No. 56 of 2025 registered at Lonavala City Police Station, Pune Rural, invoking Sections 69, 318(4), 316(2), 3(5) of the Bharatiya Nyaya Sanhita, 2023, along with Section 66E of the Information Technology Act, 2000. The complainant, a practising advocate from Mumbai, alleged that the appellant had raped her on the false promise of marriage.
Apprehending arrest, Kadam approached the Bombay High Court under Section 482 of the Bharatiya Nagarik Suraksha Sanhita, 2023, seeking anticipatory bail. The High Court rejected his plea, prompting him to approach the Supreme Court.
Supreme Court’s Observations
During the hearing, the appellant contended that the relationship was consensual, had since ended, and that neither party intended to marry. He further submitted that he was an IT professional residing in London and had been falsely implicated.
The State of Maharashtra opposed the plea, citing that a non-bailable warrant, proclamation proceedings, lookout circular, and a Blue Corner Notice had already been issued against the appellant.
The bench, however, expressed concern over the State’s actions and questioned the propriety of issuing a Blue Corner Notice in such a matter, particularly when similar measures are not pursued with equal urgency against hardened criminals.
Allowing the appeal, the Supreme Court directed that:
- In the event of arrest, the appellant shall be released on bail upon furnishing cash security of ₹25,000 with two sureties
- The appellant must fully cooperate with the investigation
- He shall not tamper with evidence or influence witnesses
- The protection will remain effective even if he travels to India for investigation or other purposes
The Court further ordered that the Look Out Notice, Blue Corner Notice, and the proclamation declaring him a proclaimed offender shall remain in abeyance.
The appeal and the connected interim application were allowed, with the bench reiterating that the interim protection earlier granted on November 17, 2025, would now stand confirmed.
About Blue Corner Notice
A Blue Corner Notice is an international alert issued by INTERPOL under its colour-coded notice system. Also known as an “enquiry notice,” it enables law-enforcement agencies of member countries to locate a person, verify identity, and collect information, including criminal records and whereabouts.
Blue Corner Notices are generally issued before formal criminal charges are filed and are used to facilitate cross-border information sharing, not arrest.
INTERPOL
INTERPOL (International Criminal Police Organization) is an independent international body that promotes cooperation among police forces worldwide to combat cross-border crimes such as terrorism, human trafficking, and organized crime.
It has 196 member countries, with India joining in 1949. INTERPOL is not part of the United Nations, but it has held Permanent Observer status at the UN since 1996. Its headquarters are located in Lyon, France.
Case Title:
PRAVEEN MANIK KADAM VERSUS STATE OF MAHARASHTRA & ANR.
SLP (CRL.) NO(S). 18345/2025
READ ORDER
Click Here to Read Our Reports on False Promise of Marriage

