Consensual Relationship Leading to Marriage Negated The Claim Of A Physical Relationship Based On A False Promise Of Marriage: Supreme Court

In a significant ruling, the Supreme Court of India, comprising Justice Abhay S. Oka and Justice Pankaj Mithal, set aside a judgment of the Allahabad High Court and quashed an FIR against Ajeet Singh, accused of rape and criminal intimidation under Sections 376 and 506 of the Indian Penal Code (IPC).

The FIR, lodged at the behest of the third respondent in Police Station Naka, District Lucknow, Uttar Pradesh, alleged that Singh had exploited the complainant’s daughter by falsely promising to marry her. The High Court had earlier declined to quash this FIR, leading to the appeal in the apex court.

In a detailed judgment, Justice Oka noted, "The relationship between the appellant and the victim was a consensual relationship which culminated in the marriage." The Court found that the allegations in the FIR were baseless and constituted an abuse of the process of law, as the consensual relationship leading to marriage negated the claim of a physical relationship based on a false promise of marriage.

The Court referred to the legal notice dated May 1, 2015, which acknowledged the marriage, and the petition filed by the appellant for restitution of conjugal rights, pending before the court. Justice Oka emphasized, "Therefore, on the face of it, the allegation that the physical relationship was maintained due to a false promise given by the appellant to marry, is without basis as their relationship led to the solemnization of marriage."

Supreme Court allowed the appeal, setting aside the judgment of the Allahabad High Court and quashing the FIR against Singh. This decision, echoing the principles laid down in the precedent case of State of Haryana & Ors. v. Bhajan Lal & Ors., highlights the Court's stance on consensual relationships and the misuse of legal provisions in personal disputes.

Date of Decision: January 03, 2024

Ajeet Singh VS State of Uttar Pradesh & Ors.