Supreme Court on False Promise of Marriage: FIR for Rape Quashed,

Headnote:

The Supreme Court quashed an FIR alleging rape on the basis of a false promise of marriage, holding that a long-term consensual relationship between adults cannot be retroactively converted into rape merely because the relationship soured later. Since the sexual relationship between the parties was consensual, emotionally involved, and not induced solely by a false promise of marriage, the continuation of criminal proceedings for rape would amount to abuse of process.

Background:

• The complainant, a married woman living separately from her husband, developed a close personal relationship with the appellant, her advocate in a maintenance case.

• Between 2022 and 2024, they met frequently and engaged in consensual sexual relations. The complainant became pregnant thrice and underwent medical termination of pregnancy each time with the appellant’s knowledge and consent.

• The complainant filed FIR No. 294/2024 alleging offences under Sections 376, 376(2)(n) and 507 IPC after the appellant refused to pay ₹1,50,000 that she allegedly demanded.

• The Bombay High Court refused to quash the FIR, following which the appellant approached the Supreme Court.

Court’s Observations:

• A consensual relationship spanning years cannot automatically become rape simply because marriage does not materialise.

• For an offence of rape based on a false promise of marriage, the promise must be the sole basis for the woman’s decision to engage in sexual relations.

• The long duration of the relationship, repeated consensual intimacy, and emotional involvement indicated voluntary participation, not exploitation.

• The FIR appeared to arise out of a later dispute, not from coercion or deception vitiating consent.

• The Court relied on Mahesh Damu Khare v. State of Maharashtra (2024) and Prashant v. State of NCT of Delhi (2025), which held that criminal law should not be used to settle personal or emotional disputes arising from failed relationships.

• Continuing the prosecution would be an abuse of process; thus the FIR and charge-sheet were quashed.

Legal Provisions Discussed:

• Section 376 & 376(2)(n), IPC – Punishment for rape; repeated sexual assault.

• Section 507, IPC – Criminal intimidation.

• Article 136, Constitution of India – Special leave to appeal.

Citation: 2025 INSC 1351

Case: Samadhan S/o Sitaram Manmothe v. State of Maharashtra & Anr.

Court: Supreme Court of India

Date of Decision: 2025

Criminal Appeal No.: 5001 of 2025 (Arising out of SLP (Crl.) No. 6906 of 2025)