Latest JudgementIndian Penal Code, 1860

Jothiragawan v. State, 2025

Supreme Court Quashes Rape Case Against Man Accused of Forcible Sex Under False Promise of Marriage

Supreme Court of India·25 March 2025

Indian Penal Code, 1860

Court

Supreme Court of India

Date of Decision

25 March 2025

Judges

Justice Sudhanshu Dhulia ⦁ Justice K. Vinod Chandran

Citation

Acts / Provisions

Section 13(1)(ia), Hindu Marriage Act, 1955

Section 25, Hindu Marriage Act, 1955

Facts of the Case

The victim accused the man, Jothiragawan, of coercing her into sexual intercourse under the false promise of marriage.
The victim claimed that after the first incident of sexual intercourse, the accused promised marriage but later refused.
Despite this promise, the victim voluntarily accompanied the accused to a hotel twice more, each time alleging coercion and force during the act.
The accused denied these allegations and stated that there was no fraudulent intention behind his promise of marriage.

Whether a breach of promise to marry automatically constitutes rape under Section 376 of the IPC?
Whether there was coercion or force used by the accused during the sexual acts?
Whether the victim's consent to accompany the accused to the hotel rooms on multiple occasions contradicted her claim of force and coercion?

The Court quashed the FIR and the ongoing criminal proceedings against Jothiragawan.
The Court found that the victim’s actions contradicted her allegations, especially her willingness to meet the accused after the alleged forced incidents.
The proceedings before the Sessions Judge (Mahila Court), Erode, were deemed to be an abuse of process and, therefore, the case was dismissed.

The Supreme Court's judgment makes it clear that consent obtained through a promise of marriage does not automatically constitute rape, especially when the alleged force or coercion is contradicted by the victim’s willingness to engage in the sexual act.
This case highlights the legal principle that a promise to marry does not alone imply coercion or fraud unless it can be proven that the promise was made with the intent to deceive from the very beginning.
The Court's decision reinforces the importance of evidence and consent in sexual offence cases, particularly those involving claims of false promises of marriage.