SC Quashes Rape Case, Cites Promise Made in Good Faith
The Supreme Court recently dismissed a rape case, emphasizing the distinction between a deliberate false promise of marriage and a genuine promise made in good faith but later unfulfilled.
A bench comprising Justices SK Kaul and MM Sundresh reviewed the case where the appellant and respondent had a consensual relationship from 2009 to 2011. The respondent alleged that the physical relationship was based on the appellant’s promise to marry her. However, the complaint was filed only in 2016, leading to an FIR under Sections 376 and 420 of the IPC.
Court’s Observation
The court deemed the FIR an “abuse of criminal process,” highlighting that both parties willingly maintained a physical relationship over a significant period without marriage. The relationship eventually ended, and the respondent took three years to file the complaint.
“We find no justification for continuing with the FIR dated 16.12.2016. Allowing further proceedings would amount to harassment of the appellant through legal channels,” the bench stated.
Reference to Previous Case
The court referenced its ruling in Pramod Suryabhan Pawar vs. State of Maharashtra (2019), where it held that a breach of a genuine promise of marriage, later unrealized due to circumstances, is distinct from a false promise made with the intention to deceive.
Final Verdict
The court set aside the earlier judgment and quashed the proceedings related to the FIR. “The appeal is allowed, and the parties will bear their respective costs,” it concluded.
This decision underscores the importance of differentiating between consensual relationships and criminal accusations stemming from unfulfilled marriage promises made in good faith.
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