No reasonable man will believe on the story which prosecutrix is narrating: High Court Quashes Rape Charges in Case of Marital Dispute

In a notable judgment, the High Court of Madhya Pradesh has quashed the rape charges against the petitioner, Sandeep Kumar Soni, stemming from a complex marital dispute. The bench, led by Hon'ble Justice Vishal Dhagat, emphasized the lack of credible evidence and inconsistencies in the prosecutrix's statements, ultimately ruling in favor of the petitioner. This decision underscores the necessity for clear and consistent testimonies in cases involving allegations of sexual assault.

The case originated from a complaint filed by the prosecutrix at the Govindpura Police Station in Bhopal, where she accused Sandeep Kumar Soni of rape under the pretext of a false promise of marriage, and subsequent threats to her life. The complaint led to charges under Sections 376(2)(n) and 506-II of the Indian Penal Code. The prosecutrix and petitioner were married on October 27, 2021, in Arya Samaj Mandir, Bhopal. The petitioner filed for nullification of the marriage shortly thereafter, claiming that the relationship was coerced and that the prosecutrix had affiliations with other individuals.

Justice Dhagat meticulously examined the prosecutrix's statements, finding significant discrepancies. "From her statement, it is clear that she did not surrender to petitioner for making sexual intercourse on believing false promise of marriage to be true," the judge noted. The prosecutrix alleged repeated forceful rapes but failed to lodge any FIRs promptly, which cast doubts on her narrative's credibility.

The court observed that the relationship between the petitioner and the prosecutrix had a longstanding history, spanning over five years. During this period, no formal complaints of rape were filed, which the court found inconsistent with the prosecutrix's allegations of continuous sexual assault under duress. "Despite forceful rape being committed by the petitioner on her repeatedly for long time, she did not lodge FIR against petitioner on the contrary she also married the petitioner," the judgment highlighted.

The legal reasoning centered around Exception 2 of Section 375 of the Indian Penal Code, which states that sexual intercourse by a man with his own wife, provided she is not under 18 years of age, does not constitute rape. The court found that the alleged incidents of rape occurred before the formalization of marriage and thus did not fall under the purview of this exception. Furthermore, the court emphasized that the prosecutrix's actions did not align with someone misled by a false promise of marriage, but rather indicated consensual actions within a troubled relationship.

Justice Vishal Dhagat remarked, "No reasonable man will believe on the story which prosecutrix is narrating before the police station regarding commission of rape on her." This statement encapsulated the court's skepticism towards the prosecutrix's claims and underscored the necessity for coherent and plausible evidence in such cases.

The High Court's decision to quash the charges against Sandeep Kumar Soni marks a significant moment in the judicial handling of cases involving complex interpersonal relationships and allegations of sexual assault. By highlighting the inconsistencies and lack of timely legal actions by the prosecutrix, the court has reinforced the importance of credible evidence in upholding justice. This ruling is expected to influence future cases, particularly those involving marital disputes and allegations of false promises of marriage.

Date of Decision: May 15, 2024

SANDEEP KUMAR SONI  VS THE STATE OF MADHYA PRADESH and VICTIM A .