The Supreme Court quashed an FIR alleging false promises of marriage, ruling that consensual relationships cannot be criminalized merely for not resulting in marriage, safeguarding individual rights.
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
Attachment:
