Consensual relationships and the implications of false promises of marriage in cases involving allegations of rape under Section 376 of IPC: Supreme Court Judgment.

Introduction

The Supreme Court of India, in the case of Rajnish Singh @ Soni v. State of U.P. & Anr. arising out of SLP (Crl.) No. 8549 of 2023, examined the issue of consensual relationships and the implications of false promises of marriage in cases involving allegations of rape under Section 376 of the Indian Penal Code, 1860 (IPC). The Court quashed the criminal proceedings, underscoring the distinction between a voluntary relationship and one vitiated by deceit.

Factual Background

The case involved a prolonged intimate relationship spanning 16 years between the complainant, a well-educated woman employed as a lecturer, and the appellant, a former police constable turned bank clerk. The complainant alleged that the appellant had first subjected her to sexual intercourse in 2006 by sneaking into her house and forcibly raping her. She further claimed that the appellant continued to exploit her under the pretext of marriage, even resorting to blackmail with intimate videos and financial extortion. However, the complainant remained silent about these incidents until the appellant married another woman in 2022, which led her to file an FIR alleging rape, criminal intimidation, and cheating.

Key Legal Issues

1. Whether the appellant’s actions constituted rape under Section 376 IPC on the ground of a false promise of marriage?
2. Whether the prolonged consensual relationship negated the allegations of coercion and deceit?
3. Whether the FIR, filed after 16 years of alleged victimization, was an abuse of legal process?

Judicial Reasoning and Decision

The Supreme Court, while quashing the FIR and subsequent criminal proceedings, emphasized the following:

1. Delay in Filing the FIR: The Court noted that the complainant, a mature and educated woman, had continued her relationship with the appellant voluntarily over a significant period. The delay of 16 years in filing the complaint weakened her claims of coercion.
2. Nature of Relationship: The Court found that the complainant frequently visited the appellant at different locations, portraying herself as his wife in certain instances. This indicated a consensual relationship rather than one predicated on deceit.
3. No Misconception of Fact: Relying on precedents such as Deepak Gulati v. State of Haryana (2013) 7 SCC 675 and Mahesh Damu Khare v. State of Maharashtra (2024 SCC OnLine SC 3471), the Court reiterated that for a promise of marriage to vitiate consent under Section 375 IPC, there must be clear evidence that the accused never intended to marry the complainant from the outset. In this case, the evidence suggested otherwise.
4. Precedents on False Promises of Marriage: The Court cited Prashant v. State (NCT of Delhi) (2024 SCC OnLine SC 3375), where it was held that a long-standing relationship, where both parties had the autonomy to make informed choices, cannot later be construed as rape due to a broken promise.
5. Abuse of Process of Law: The Court held that allowing prosecution to continue in this matter would amount to an abuse of legal proceedings, as the allegations were found to be motivated by personal vendetta after the appellant married another woman.

Conclusion

This judgment reinforces the principle that consent in a sexual relationship must be examined in light of the facts and circumstances surrounding the parties. The Court has drawn a clear distinction between cases where a false promise of marriage is used as a tool for exploitation and cases where an adult, capable of making independent decisions, engages in a consensual relationship. The decision sets a significant precedent in protecting individuals from frivolous litigation stemming from relationships that later turn sour.

References

1. Rajnish Singh @ Soni v. State of U.P. & Anr., 2025 INSC 308.
2. Deepak Gulati v. State of Haryana, (2013) 7 SCC 675.
3. Mahesh Damu Khare v. State of Maharashtra, 2024 SCC OnLine SC 3471.
4. Prashant v. State (NCT of Delhi), 2024 SCC OnLine SC 3375.
5. Shivashankar v. State of Karnataka, (2019) 18 SCC 204.