Madhya Pradesh High Court Quashes Rape Case, Rules Married Woman’s Consent Not Based on False Promise of Marriage

In a recent ruling, the Madhya Pradesh High Court has dismissed a rape case filed by a married woman against a man, stating that her consent for a sexual relationship was not based on a false promise of marriage. The case, Veerendra Yadav v. The State of Madhya Pradesh, was quashed by Justice Maninder S. Bhatti after examining the facts presented by the complainant.

Key Observations and Judgment

• Court’s Ruling on False Promise of Marriage
  • The Court stated that married women cannot claim that their consent for a physical relationship was taken under the pretext of a false promise of marriage.
  • Justice Bhatti referred to previous judgments, including those of the Apex Court, and concluded:
    “When the prosecutrix is a married lady, her consent for a physical relationship on the garb of a false promise of marriage cannot be brought within the framework of consent obtained on the basis of misconception of the fact.”
• The Accusations and Relationship Background
  • The complainant was married to a driver and had two children. She alleged that the accused, who was also married, had promised to marry her after divorcing his wife, leading to the establishment of a sexual relationship over a period of three months.
  • The complainant claimed that after the accused declined to marry her, citing his inability to divorce his wife, she filed the rape complaint.
• Court’s Scrutiny of Evidence
  • The Court carefully examined the complainant's statement and found no evidence of coercion or misconception.
  • It was noted that the complainant had engaged in the sexual relationship voluntarily when her husband was away, and that there were no specific allegations of pressure being applied by the accused.
  • “Therefore, it cannot be said that the consent was given by the prosecutrix under some misconception of fact.”
• FIR Scrutiny and Case Dismissal
  • The Court pointed out that the FIR did not contain any clear allegations that the accused had promised marriage as a precondition for the sexual relationship.
  • The ruling emphasized that such cases should be dismissed early to prevent unnecessary legal proceedings.
  • “In such a case, the FIR is required to be nipped in the bud, as the same would entail in the long drawn process of conduct of trial whereas the allegations levelled in the FIR on their face value, do not indicate the commission of offence under the aforesaid sections.”
• Advocates Representing the Case
  • Advocate Shreyash Pandit represented the accused, and Deputy Government Advocate Shailendra Mishra represented the State in the case.

Case Title: Veerendra Yadav v State of Madhya Pradesh

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