Supreme Court Quashes Rape Allegation: Differentiates Consensual Relationships from Criminal Misconduct in False Promise of Marriage Case

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The Supreme Court of India, on November 20, 2024, quashed an FIR filed against a man accused of repeatedly raping a woman under the false pretext of marriage. The Court emphasized that the non-materialization of a consensual relationship into marriage cannot be criminalized. This landmark ruling clarifies the distinction between consensual relationships and criminal actions, especially in cases involving allegations of false promises of marriage.

A bench comprising Justice B.V. Nagarathna and Justice N. Kotiswar Singh ruled that:
"A mere breakup of a relationship between a consenting couple cannot result in initiation of criminal proceedings. What was a consensual relationship between the parties at the initial stages cannot be given a colour of criminality when the said relationship does not fructify into a marital relationship."

Background of the Case

• The complainant filed an FIR in September 2019, alleging that the appellant had sexually exploited her under the false promise of marriage.
• She further claimed that the appellant had threatened to harm her family if she refused to engage in physical relations.
• The appellant was booked under Sections 376(2)(n) (repeated rape) and 506 (criminal intimidation) of the Indian Penal Code (IPC).

Legal Journey of the Case

• The appellant approached the Delhi High Court, seeking to quash the FIR under Section 482 CrPC.
• The High Court dismissed the petition, holding that there was sufficient prima facie evidence to proceed with the case.
• However, the Supreme Court, upon reviewing the case, found that the allegations lacked merit and noted significant contradictions in the complainant’s narrative.

Key Observations by the Supreme Court

• Consensual Relationship:
  The Court determined that the relationship between the complainant and the appellant was consensual and not initiated under any false promise of marriage.
  • It observed: “There was no indication that the relationship commenced with a promise of marriage.”
  • The Court further noted that the parties were educated adults who continued meeting even after the alleged incidents of forced sexual encounters.
• FIR and Section 164 CrPC Statement:
  Upon reviewing the FIR and the complainant’s Section 164 CrPC statement, the Court found no evidence of any explicit promise of marriage at the outset of their relationship in 2017.
  • It stated: “Even if the prosecution's case is accepted at its face value, it cannot be concluded that the complainant engaged in a sexual relationship with the appellant solely on account of any assurance of marriage from the appellant.”
• Lack of Evidence for IPC Sections 376(2)(n) and 506:
  The Court held that the ingredients for the offenses under Sections 376(2)(n) and 506 IPC were not established in this case.
  • It stated: “The High Court erred in concluding that there was no consent on the part of the complainant and, therefore, she was a victim of sexual assault.”

Supreme Court’s Decision

• The bench ruled that the High Court misinterpreted the facts, leading to an incorrect dismissal of the appellant’s plea under Section 482 CrPC.
• It noted that continuing the prosecution in this case would amount to an abuse of the court’s process.
• The appeal was allowed, and the pending FIR was quashed.

Legal Implications of the Judgment

• Clear Differentiation Between Consent and Criminality:
  The ruling reinforces that consensual relationships, even if they end without marriage, cannot automatically lead to criminal proceedings.
• Preventing Misuse of Legal Provisions:
  This judgment safeguards against the misuse of Section 376 IPC by ensuring that allegations of false promises of marriage are thoroughly scrutinized before proceeding with criminal charges.
• Higher Bar for Prosecution in Consensual Cases:
  The judgment sets a precedent for evaluating whether criminal charges are justified when allegations arise from consensual relationships.

Representation in Court

• For the Petitioner:
  Dr. Sunil Kumar Agarwal, Mr. Nikhil Tyagi, Mr. Atul Agarwal, Mr. Rakesh Kumar Khare, Ms. Kirti Sharma, and Mrs. Amita Agarwal.
• For the Respondent:
  Mr. Vikramjeet Banerjee (ASG), Mr. Mukesh Kumar Maroria, Mr. Ajay Kumar Prajapati, Mr. Ayush Anand, Mr. Annirudh Sharma, and Mr. Veer Vikrant Singh.

Case Title: PRASHANT VERSUS STATE OF NCT OF DELHI

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