Supreme Court Quashes FIR Alleging Rape on False Promise of Marriage After 16-Year Relationship

New Delhi, March 3, 2025 – The Supreme Court of India has quashed an FIR against a man accused of rape under a false promise of marriage, holding that a 16-year consensual relationship cannot be retrospectively converted into a case of sexual assault merely because marriage did not take place.

Delivering the judgment in Rajnish Singh @ Soni v. State of Uttar Pradesh & Anr., a bench of Justices Vikram Nath and Sandeep Mehta observed, "An intimate relationship that lasted over a decade and a half, involving a mature and educated woman, cannot later be claimed as non-consensual solely due to the failure of marriage. A case of rape is made out only if the promise was false from the very beginning, which has not been established here."

The Court also questioned the complainant's credibility, noting that she continued the relationship despite knowing that the accused had married another woman. It held that allowing prosecution in such cases would amount to an "abuse of the process of law" and emphasized that "the sanctity of criminal law must not be diluted to settle personal grievances arising out of failed relationships."

Complainant Filed FIR After 16 Years of Relationship, SC Says Delay Raises Serious Doubts

The case originated from an FIR lodged on July 5, 2022, at Police Station Bakewar, District Etawah, Uttar Pradesh. The complainant alleged that the accused had established sexual relations with her in 2006 under the promise of marriage and later blackmailed her with explicit videos.

The Court took note of the unexplained delay in filing the FIR and stated, “The complainant remained silent for 16 years and only approached the police when she learned that the appellant had married another woman. Such a prolonged delay raises serious doubts about the authenticity of the allegations and suggests that the FIR is a product of personal vendetta rather than an actual criminal offense.”

It also observed that the prolonged nature of the relationship negates the claim of coercion. "A woman cannot claim that she was deceived into a sexual relationship spanning over 16 years. If the promise of marriage was the sole reason for consent, she would not have continued the relationship despite clear indications that the accused was moving on," the Court remarked.

False Promise of Marriage Cannot Be Presumed Without Evidence of Fraudulent Intent, Says SC

The Supreme Court referred to multiple precedents and reaffirmed that a breach of promise to marry does not amount to rape unless it is proven that the promise was false from the outset.

Quoting from Deepak Gulati v. State of Haryana (2013) 7 SCC 675, the Court reiterated, “A distinction must be drawn between a false promise to marry and a mere breach of promise. A man cannot be held guilty of rape merely because circumstances prevented him from fulfilling a promise made in good faith.”

It further cited Prashant v. State (NCT of Delhi), 2024 SCC OnLine SC 3375, stating, “Sexual relations that continue for several years in a consensual setting cannot suddenly be deemed as rape based on the ultimate outcome of the relationship.”

Addressing the specific facts of the case, the Court found that the complainant had, at multiple points, referred to herself as the wife of the appellant and had even attempted to stop his marriage to another woman. "The complainant’s conduct shows that she was not a helpless victim, but an equal participant in the relationship. If the promise of marriage was false from inception, she would not have waited for 16 years before lodging a complaint," the Court said.

Supreme Court Sets Aside High Court Order, Quashes FIR Against the Accused

In a decisive ruling, the Supreme Court set aside the Allahabad High Court’s order and quashed FIR No. 269 of 2022, along with all criminal proceedings pending against the appellant. The Court made it clear that criminal law cannot be weaponized to seek retribution for failed relationships.

“Consent, once given with full awareness, cannot be revoked years later under the pretext of misconception. If we allow such cases to proceed, it will open the floodgates for misuse of rape laws and weaken their legitimacy in genuine cases of sexual assault,” the bench concluded.

With this judgment, the Supreme Court has reinforced the legal distinction between consensual relationships and cases of sexual assault, emphasizing that not every failed relationship can be turned into a criminal case.