The Supreme Court of India, in a judgment delivered on 12 March 2025, quashed an FIR alleging rape on the basis of a false promise of marriage where the parties had maintained a sexual relationship for 16 years. The Bench of Justice Vikram Nath and Justice Sandeep Mehta held that the prolonged and uninterrupted nature of the relationship negated any inference of force or deception.
Background
The complainant had lodged FIR No. 269 of 2022 alleging that the appellant first established physical relations with her in 2006, promising marriage, and continued the relationship over a period of 16 years through threats and blackmail. She further alleged that the appellant had recorded intimate videos and used them as leverage. In 2022, upon discovering that the appellant had married another woman, she filed a complaint under Sections 376, 384, 323, 504, and 506 of the Indian Penal Code.
The appellant moved the Allahabad High Court for quashing of the FIR, but the petition was dismissed. The matter then reached the Supreme Court by way of special leave.
The legal question at the core of the case was whether a prolonged consensual relationship, later characterised as rape upon its breakdown, could sustain a prosecution under Section 376 IPC.
Key Holdings
The Supreme Court laid down the following principles:
Duration negates force: A continuous sexual relationship spanning 16 years was sufficient to conclude that the relationship was consensual and that no element of force, coercion, or deceit was involved at any point.
Breach of promise distinguished from initial deception: The Court reaffirmed that a mere breach of a promise to marry does not amount to rape. To constitute rape, the accused must have made the promise with no intention of fulfilling it at the very inception of the relationship.
Complainant's qualifications considered: The Court observed that the complainant was a highly qualified individual, making it difficult to accept the contention that she was continuously exploited against her will over such an extended period.
Complete quashing: The FIR and all consequential proceedings were quashed and set aside in their entirety.
Implications for Practitioners
This judgment reinforces the settled position that the duration and nature of a relationship are critical factors in determining whether allegations of rape based on a false promise of marriage can be sustained. Defence counsel handling similar matters should document the chronological timeline of the relationship with specificity, as the Court placed significant weight on the unbroken 16-year period.
Practitioners should note the Court's observation regarding the complainant's educational background and professional capacity. While this factor alone would not be determinative, it was used to assess the plausibility of the allegation that consent was vitiated over such a lengthy period.
For prosecution agencies, the judgment signals that filing rape charges in the context of relationship breakdowns requires careful assessment of whether the foundational element of deception existed at the inception of the relationship, not merely at its conclusion. Routine registration of FIRs in such matters without this threshold assessment may result in quashing by higher courts.