Grown-Up Lady...Intelligent Enough to Understand Consequences: Supreme Court Quashes Rape FIR, Highlights Complainant’s Maturity in Consent

In a significant judgment, the Supreme Court of India, comprising Justices C.T. Ravikumar and Rajesh Bindal, quashed an FIR and subsequent proceedings against the appellant in a case involving allegations of rape under the pretext of a false promise to marry.

The legal pivot of the case revolved around the interpretation of consent in the context of Section 375 of the IPC and the legitimacy of invoking Section 376(2)(n) and 506 IPC under the alleged circumstances. The Court meticulously analyzed the essence of consent and the role of misconception in determining the nature of the relationship between the appellant and the complainant.

The case emerged from an FIR filed by the complainant, alleging that the appellant had physical relations with her under a false promise of marriage. The complainant, a divorced woman with a child, claimed to have been deceived into a physical relationship by the appellant. However, discrepancies in her statements and actual facts raised questions over the credibility of the allegations.

Analysis of Consent: The Court observed that the relationship was consensual, and the complainant was not under any misconception at the time of giving consent. The judgment noted, “It is not a case where the complainant was of an immature age who could not foresee her welfare and take right decision. She was a grown-up lady... intelligent enough to understand the consequences.”

Evaluation of Evidence: The Court pointed out significant inconsistencies in the complainant’s testimony regarding her marital status and the timeline of events. These discrepancies cast doubt on the allegation of rape under a false promise to marry.

Precedent: The Court referred to similar cases, including Naim Ahamed v. State (NCT of Delhi) 2023 SCC OnLine SC 89, where it was held that a mature person cannot claim to be under misconception of fact while giving consent for a sexual relationship.

The Supreme Court allowed the appeal, quashing the FIR No.52 dated 11.12.2020, registered at the Police Station, Mahila Thana, District Satna (M.P.), along with all subsequent proceedings. The Court underscored that the initiation of proceedings against the appellant was an abuse of the process of law.

Date of Decision: March 6, 2024

XXXX v. State of Madhya Pradesh & Another