Woman Cannot File Rape Case Just Because Relationship Didn’t Lead to Marriage: Madhya Pradesh High Court
In a key judgment, the Madhya Pradesh High Court ruled that a woman cannot file a rape case simply because a long-term consensual relationship did not end in marriage.
The case was reviewed by Justice Sanjay Dwivedi of the Jabalpur Bench, who made it clear that not all failed relationships can be seen as criminal cases. The judge highlighted the legal difference between a false promise meant to deceive and a genuine promise that could not be fulfilled.
The man and the complainant were in a consensual relationship for ten years, starting in high school. The woman alleged that he had promised to marry her but later changed his mind. In 2021, she filed an FIR accusing him of rape on the grounds that he misled her.
Justice Dwivedi said that courts have repeatedly held that just because a relationship ends without marriage does not make it rape. He explained that many young couples believe their relationship will end in marriage, but when that doesn’t happen, it does not mean a crime occurred.
The court noted that the couple had a long, consensual relationship and that the woman never complained until the man refused to marry her. This, the court said, proves that there was no force or fraud involved.
“The relationship lasted for 10 years with mutual consent. It is hard to believe that the man tricked the woman into a physical relationship just to avoid marriage,” the judge said.
He added that sometimes, a person might truly want to marry someone but cannot due to unavoidable reasons. In such situations, it’s wrong to assume the person was lying or intended to deceive.
The court clarified that for a claim to be considered rape due to “misconception of fact” under Section 90 of the Indian Penal Code, the misunderstanding must exist at the time the consent was given. That wasn’t the case here.
Because of this, the court dismissed the criminal case and said the conditions required under Section 375 of the IPC for rape were not met.
In conclusion, the court said: “This case clearly shows a consensual relationship. Since both parties agreed to it and it lasted many years, it cannot be treated as rape just because it didn’t lead to marriage.”
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