Conviction for Rape on Promise to Marry Quashed as Couple Marries: Supreme Court Invokes Article 142 to Do Complete Justice

“Consensual Relationship Misunderstood as Crime Due to Delay in Marriage”— In a notable exercise of its extraordinary constitutional powers, the Supreme Court of India quashed the conviction and sentence of Sandeep Singh Thakur under Sections 376(2)(n) and 417 of the Indian Penal Code after the prosecutrix married the appellant during the pendency of the criminal appeal.

A Bench comprising Justice B.V. Nagarathna and Justice Satish Chandra Sharma, in an appeal arising from the Madhya Pradesh High Court’s refusal to suspend the appellant’s sentence, observed that the parties had since married and were residing together happily. In these “exceptional circumstances,” the Court exercised its powers under Article 142 of the Constitution to “do complete justice” by quashing the FIR, the trial court’s conviction and sentence, and the pending appeal itself.

The Court remarked, “We think that owing to a misunderstanding, the consensual relationship between the parties was given a criminal colour and converted into an offence of false promise of marriage, whereas the parties, in fact, intended to marry each other.”

“This Is One of Those Rare Cases Where Conviction Ends in Marriage, Not Incarceration”

At the heart of the case lies a relationship that began in 2015 via social media between the appellant and the prosecutrix, which developed into a consensual physical relationship. The prosecutrix later filed FIR No. 29 of 2021 alleging that the appellant had sexual relations with her on a false promise of marriage. The trial ended in the appellant’s conviction under Section 376(2)(n) IPC, with a sentence of 10 years’ rigorous imprisonment and a fine of ₹50,000, and under Section 417 IPC, with a two-year sentence and ₹5,000 fine.

The appellant’s appeal (CRA No. 4869/2024) before the Madhya Pradesh High Court was pending when the High Court rejected his application for suspension of sentence on 5th September 2024. This led to the appeal before the Supreme Court.

But what began as a routine criminal appeal took a dramatic and transformative turn.

“We Had a Sixth Sense That They Could Reconcile”— Justices Intervene Personally to Facilitate Marriage

The turning point came when the Supreme Court, during an early hearing, sensed that the matter might be amenable to amicable resolution.

The Court candidly recorded, “We had a sixth sense that the appellant and the respondent prosecutrix could be brought together once again if they decided to marry each other.”

Accordingly, both parties and their parents were summoned to the Court. The Bench interacted with them in chambers, encouraging open dialogue. On 15th May 2025, the Court noted that both parties “unequivocally stated” their willingness to marry, and interim bail was granted to the appellant to facilitate the wedding.

The marriage was solemnised on 22nd July 2025, and by the next hearing, the parties had begun living together.

“Interest of Justice Requires Quashing of Conviction”— Court Nullifies FIR, Trial, and Appeal Using Article 142

Recognising that both parties were now married and had no desire to continue with the criminal proceedings, the Court observed that further prosecution would serve no purpose.

In its ruling, the Bench held:

“In the interest of justice, FIR No. 29 of 2021 dated 02.11.2021, the judgment of the Additional Sessions Judge, Sagar, and the order of conviction and sentence passed on 12.04.2024, stand quashed.”

The Court added that CRA No. 4869/2024 pending before the Madhya Pradesh High Court had become infructuous and disposed of the matter accordingly.

“Suspension of Government Service Revoked—Salary Arrears to Be Paid Within Two Months”

The appellant, who had been suspended from his government service following the conviction, was also granted relief by the Supreme Court. The Court directed the Chief Medical Officer, Sagar (MP) to revoke the suspension order and pay all pending salary arrears to the appellant within two months.

“The learned standing counsel for the State shall convey this order to the concerned officer for compliance.”

“Not Every Relationship Gone Wrong Is a Criminal Offence”— A Cautionary Note on Criminalising Intimate Relations

The Supreme Court’s nuanced observation that “a consensual relationship was given criminal colour owing to a misunderstanding and delay in marriage” underscores the increasing complexity of legal disputes emerging from failed relationships.

The Court was careful to highlight that it does not lay down a precedent that marriage can erase criminal liability, but rather, in the peculiar facts of this case, where both parties chose to reconcile, justice would best be served by quashing the proceedings.

“Complete Justice Is Not Just Legal Justice, But Equitable Resolution”

By invoking Article 142, the Court reasserted its plenary powers to ensure substantive and equitable justice—even if it means setting aside a criminal conviction. In doing so, it also acknowledged that the criminal law machinery must not be used to perpetuate personal vendetta or misinterpret consensual acts as offences when the underlying dispute no longer exists.