SUPREME COURT RULING ON CONSENSUAL RELATIONSHIPS AND FALSE PROMISES OF MARRIAGE

by | Mar 4, 2025

 Supreme Court of India ruling on consensual relationships and false promises of marriage in Rajnish Singh case.

Supreme Court quashes FIR against Rajnish Singh, ruling that long-term consensual relationships cannot be classified as rape based on unfulfilled marriage promises


SUPREME COURT RULING ON CONSENSUAL RELATIONSHIPS AND FALSE PROMISES OF MARRIAGE


ASPECTS DETAILS
Case Title Rajnish Singh @ Soni vs. State of U.P. and Another (2025 INSC 308)
Introduction The case involves an appeal against the Allahabad High Court’s order dismissing the quashing petition filed under Section 482 CrPC  which states about  Supreme Court ruling on consensual relationships and false promises of marriage . The appellant sought to quash proceedings related to charges under Sections 376, 384, 323, 504, and 506 IPC.
Factual Background The complainant alleged that the appellant subjected her to sexual assault in 2006, promising marriage. Their relationship continued for 16 years, during which the appellant allegedly drugged her, filmed objectionable videos, blackmailed her, and coerced her into financial transactions. The appellant later married another woman, leading the complainant to file an FIR.
Legal Issues
  • Whether prolonged consensual sexual relations under an unfulfilled promise of marriage constitute rape.
  • Whether the appellant’s actions amount to coercion and blackmail under IPC provisions.
  •  Whether the delay in filing the FIR weakens the complainant’s case.
  • Whether allegations of financial exploitation are substantiated.
Applicable Law
  1. Indian Penal Code (IPC): Sections 376 (rape), 384 (extortion), 323 (voluntarily causing hurt), 504 (intentional insult), 506 (criminal intimidation).
  2. Code of Criminal Procedure (CrPC): Sections 161, 164, 173(2), 482.
  3. Case precedents: Mahesh Damu Khare vs. State of Maharashtra (2024 SCC OnLine SC 3471), Prashant vs. State (NCT of Delhi) (2024 SCC OnLine SC 3375), Deepak Gulati vs. State of Haryana (2013) 7 SCC 675, Shivashankar vs. State of Karnataka (2019) 18 SCC 204.
Analysis The Court found inconsistencies in the complainant’s statements. The prolonged relationship over 16 years, where both parties engaged in consensual intimacy, raised doubts about coercion. The complainant, an educated adult, did not report the incidents until the appellant married another woman, weakening her claim of deception. The FIR appeared to be an outcome of a failed relationship rather than a genuine criminal act.
Conclusion The Supreme Court quashed the criminal proceedings, ruling that the appellant cannot be prosecuted under Section 376 IPC for a long-standing consensual relationship. The allegations lacked credibility due to the complainant’s contradictory claims and the significant delay in reporting.
Current Scenario The Supreme Court overturned the Allahabad High Court’s order, quashing FIR No. 269 of 2022 and related proceedings. The case reaffirmed that false promises of marriage cannot be a basis for rape charges in consensual relationships.

CASE SUMMARY – In this case, Supreme Court of India quashed FIR No. 269 of 2022 filed against Rajnish Singh under Sections 376, 384, 323, 504, and 506 IPC. The complainant alleged that the appellant sexually exploited her over 16 years under a false promise of marriage. However, the Court found that the relationship was consensual, lasted over a decade, and the complainant’s delay in filing the FIR weakened her case. Referring to legal precedents, the Court ruled that consensual relationships cannot be categorized as rape unless coercion is proven. The Allahabad High Court’s decision was set aside, and all proceedings were quashed.

“THE SUPREME COURT REAFFIRMS THAT FALSE PROMISES OF MARRIAGE CANNOT BE A BASIS FOR RAPE CHARGES IN CONSENSUAL RELATIONSHIPS.”

SOURCE- SUPREME COURT OF INDIA

 

 

Written By Nancy Sharma

I am Nancy Mahavir Sharma, a passionate legal writer and a judicial service aspirant who is interested in legal researching and writing. I have completed Latin Legum Magister degree. I have been writing from past few years and I am excited to share my legal thoughts and opinions here. I believe that everyone has the potential to make a difference.

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