Prashant Pal vs State of Uttar Pradesh, 2026
The Court relied on Supreme Court precedents to clarify the legal definition of “false promise” and its effect on consent.
Judgement Details
Court
Allahabad High Court
Date of Decision
5 January 2026
Judges
Justice Nalin Kumar Srivastava
Citation
Acts / Provisions
Section 13(1)(ia), Hindu Marriage Act, 1955
Section 25, Hindu Marriage Act, 1955
Facts of the Case
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Accused Prashant Pal allegedly engaged in sexual relations with the victim under the false promise of marriage.
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The relationship reportedly lasted five years, during which the accused subjected the victim to physical and mental torture.
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Despite the long-term relationship, the accused refused to marry the victim and got engaged to another woman.
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Accused moved the High Court seeking anticipatory bail, claiming:
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Allegations are vague and false.
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Both parties were adults in a consensual relationship since 2020.
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He never promised marriage, and refusal to marry does not constitute a crime.
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State opposed the plea, arguing:
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Sexual relations were obtained on a false pretext of marriage.
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Medical evidence corroborated the victim’s claim of sexual violence.
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Accused threatened the victim with obscene videos.
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High Court examined Supreme Court precedents:
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A false promise is considered such if there was no intention to fulfill it at the time of making it.
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Deceiving a woman into sexual relations vitiates her consent.
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Court concluded that accused’s conduct showed fraudulent intention from the beginning, exploiting the victim for sexual gratification.
Issues
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Whether obtaining sexual intercourse on a false promise of marriage constitutes a criminal offense under BNS Section 69?
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Whether the refusal to marry after a consensual long-term relationship absolves the accused of criminal liability?
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Whether anticipatory bail can be granted in cases involving sexual exploitation under false promises of marriage?
Held
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Accused acted with fraudulent intent from inception.
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Exploiting the victim under the false pretext of marriage falls squarely within criminal misconduct under BNS Section 69.
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No indulgence (such as anticipatory bail) can be granted in such circumstances.
Analysis
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Court relied on Supreme Court precedents to clarify the legal definition of “false promise” and its effect on consent.
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Reinforced the principle that consent obtained under misconception of fact (intentional deception) is invalid.
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The decision highlights the judiciary’s societal role in curbing sexual exploitation through fraudulent promises.
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Sets a strong precedent discouraging long-term deception in intimate relationships.
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Upholds a protective approach toward victims, emphasizing psychological and social harm beyond mere physical acts.