Supreme Court Quashes Rape Case Based on Promise of Marriage Made in Good Faith
The Supreme Court of India has quashed a rape case, ruling that a promise to marry made in good faith, even if not fulfilled later, is not the same as a false promise. The court made this clear while deciding a criminal appeal in the case of Mandar Deepak Pawar vs The State of Maharashtra & Anr.
The bench, which included Justices SK Kaul and MM Sundresh, said that there is a clear legal difference between a false promise and a genuine promise that couldn’t be kept due to circumstances.
In this case, the man (appellant) and the woman (respondent) were in a consensual relationship between 2009 and 2011. The woman later claimed that the physical relationship happened only because the man had promised to marry her. However, she filed a complaint only in 2016. Based on her complaint, a First Information Report (FIR) was registered on December 16, 2016, under Sections 376 (rape) and 420 (cheating) of the Indian Penal Code.
The court noted that the FIR seemed to be a misuse of the legal process. The judges pointed out that the couple had willingly been in a relationship without getting married for a long time, and that they eventually separated — something that can happen both before and after marriage. Waiting three years after the breakup to file the complaint raised serious doubts.
The court said, “Allowing this FIR to continue would only cause unnecessary harassment to the man through the legal system.”
The judgment also referred to an earlier case (Pramod Suryabhan Pawar vs State of Maharashtra, 2019), where the Supreme Court had ruled in favor of quashing an FIR under similar circumstances. That ruling clarified that a breach of a genuine promise is not the same as making a false promise just to mislead someone.
In conclusion, the court set aside the earlier order, quashed the FIR dated December 16, 2016, and ended all proceedings in the matter. Both parties were directed to bear their own legal costs.
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