Recently, the Supreme Court quashed rape proceedings arising from a long-term relationship, holding that criminal law cannot be invoked to criminalise a consensual relationship that later turned acrimonious. The Court reiterated that Section 376 IPC must not become a tool to convert failed relationships into allegations of rape, especially when no evidence shows coercion, deceit, or a false promise of marriage from the inception.
Brief Facts:
The case concerned a woman who, after facing matrimonial disputes with her husband, came into contact with the appellant, a practising advocate. Their interactions gradually developed into a close personal relationship, and over the next three years they remained in regular communication, met frequently, and engaged in physical intimacy on multiple occasions. During this period, the woman conceived thrice, and all pregnancies were medically terminated with mutual consent.
According to the prosecution story, the relationship soured only when the appellant allegedly refused to marry her and declined to pay a monetary sum she demanded. Nearly three months after their last meeting, she lodged an FIR accusing him of rape on the ground that he had engaged in physical relations with her on a false promise of marriage.
Contentions of the Appellant:
The appellant argued that the relationship was entirely consensual and continued for several years without any allegation of coercion or deceit. It was submitted that the complainant was a well-educated woman, still legally married during the entire period of the relationship, and that she had never raised any grievance until the alleged monetary dispute arose. The appellant asserted that the FIR was an abuse of criminal process initiated only after he declined to pay the amount demanded by the complainant.
Contentions of the Respondent:
The State opposed the plea for quashing and submitted that the allegations disclosed a cognisable offence warranting a full trial. It was argued that whether the consent was voluntary or induced by a false promise of marriage could only be determined after evidence was led. The Amicus Curiae also supported the State, contending that the matter required adjudication during trial and not at the threshold.
Observations of the Court:
The Court undertook an extensive examination of the FIR, statements, and the legal principles governing consent, false promises of marriage, and the ambit of Section 376(2)(n) IPC.
The Court emphasised that the offence of rape cannot be used retrospectively to criminalise a relationship that was voluntary in nature, “The present case is not one where the appellant lured the complainant solely for physical pleasures and then disappeared. The relationship continued for three long years and the parties remained close and emotionally involved. Physical intimacy during a functioning relationship cannot be branded as rape merely because the relationship did not culminate in marriage.”
The Court expressed serious concern over the growing pattern of broken relationships being given the colour of criminality, “Such misuse of the criminal justice machinery trivialises the gravity of the offence of rape and inflicts grave injustice upon the accused.” The Bench relied on recent precedents reiterating that a consensual relationship, even if prolonged, does not become rape unless it is shown that the man never intended to marry the woman from the outset and used a false promise solely to obtain consent, “A false promise of marriage must be shown to have been made at the inception with an intent to deceive. Consent given due to love, emotional bonding, or personal reasons cannot be treated as consent vitiated by misconception of fact.”
Importantly, the Court noted multiple circumstances that contradicted the prosecution’s claim: the complainant’s own resistance to marriage for a substantial period, her voluntary meetings with the appellant, her subsisting marriage, and the complete absence of allegations during the three-year relationship. The Court further highlighted the absence of any material suggesting coercion, inducement, or deceit, “The FIR is silent on any circumstance indicating that the complainant was compelled or deceived into accompanying the appellant. Her continued voluntary association demonstrates that the relationship was consensual.”
Applying the principles laid down in Bhajan Lal, the Court held that even if the allegations were taken at face value, they did not prima facie constitute the offence of rape.
The decision of the Court:
The Apex Court allowed the appeal, set aside the order of the Bombay High Court, and held that permitting the prosecution to continue would amount to an abuse of the court’s process. It ruled that the relationship was consensual, lacked the ingredients of rape or repeated rape under Section 376(2)(n) IPC, and could not be criminalised merely because it ended on a bitter note.
Consequently, the Court quashed FIR and the subsequent chargesheet, bringing the criminal proceedings to an end. The Court also recorded its appreciation for the assistance rendered by the Amicus Curiae.
Case Title: Samadhan S/O Sitatram Manmothe vs. State of Maharasthra & Another
Case No.: Special Leave Petition (Crl.) No.6906 of 2025
Coram: Justice B.V. Nagarathna, Justice R. Mahadevan
Advocate for Petitioner: Adv. Sneha Sanjay Botwe (AOR), Bharat S. Doifode, Siddharth S. Chapalgaonkar, Akash Tripathi, Ashraf Patel
Advocate for Respondent: Adv. Aaditya Aniruddha Pande (AOR), Siddharth Dharmadhikari, Shrirang B. Varma, Bharat Bagla, Sourav Singh, Aditya Krishna, Adarsh Dubey, Chitransha Singh Sikarwar, Radhika Gautam (AOR)
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