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Latest JudgementIndian Penal Code, 1860

Rajnish Singh @ Soni Vs. State of U.P. and Another, 2025

Quashing of criminal proceeding for rape accusation based on a false promise of marriage after a 16-year consensual relationship.

Supreme Court of India·4 March 2025
Rajnish Singh @ Soni Vs. State of U.P. and Another, 2025
Indian Penal Code, 1860
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Judgement Details

Court

Supreme Court of India

Date of Decision

4 March 2025

Judges

Justices Vikram Nath ⦁ Sandeep Mehta

Citation

Acts / Provisions

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

Section 25, Hindu Marriage Act, 1955

Facts of the Case

  • Parties Involved:
    • Appellant: Rajnish Singh @ Soni, the accused.
    • Respondent: State of U.P. (for the complainant’s allegations).
  • Background:
    • The complainant and the appellant were in a 16-year consensual sexual relationship.
    • The complainant accused the appellant of sexual assault under the pretext of marriage.
    • The complainant filed an FIR in 2022 alleging rape by the appellant, claiming that he subjected her to forcible sexual intercourse after making a false promise of marriage.
    • The appellant, however, argued that the relationship was consensual and that the complainant fabricated the allegations after he married another woman.
    • 16 years passed between the alleged first act of sexual intercourse and the filing of the FIR.
    • The complainant had on multiple occasions referred to herself as the wife of the appellant, which contradicted her claims in the FIR.
    • The Court noted that the complainant did not report any of the alleged abuse during the entire 16-year period.
    • The accused appealed to the Supreme Court after the High Court dismissed his petition to quash the criminal proceedings.

Issues

  1. Whether a 16-year consensual relationship can be classified as rape based on a false promise of marriage?
  2. Whether a long delay of 16 years in filing the rape case raises doubts about the credibility of the complainant’s allegations?
  3. Whether the allegations of sexual assault were fabricated after the appellant's marriage to another woman?
  4. Whether the consent given by the complainant throughout the relationship vitiated the rape claim based on a false promise of marriage?
  5. Whether continuing criminal proceedings would amount to abuse of process of law?

Held

  • The Court reiterated that a breach of promise does not automatically constitute rape unless deceit or fraud was evident from the beginning.
  • The Court expressed surprise at the delay of 16 years in filing the complaint and pointed out that the complainant had lived with the appellant for 16 years, often referring to herself as his wife.
  • The Court found that the relationship between the complainant and the appellant was a consensual affair and concluded that there was no element of force or deceit involved during the entire duration of the relationship.
  • The Court concluded that the continuation of the criminal proceedings against the appellant would be an abuse of process and would amount to a misuse of legal provisions.

Analysis

  • The Court’s judgment stresses that a long-term consensual relationship cannot be retroactively redefined as rape based on the false promise of marriage unless there is clear evidence of deception.
  • The Court also emphasized the importance of consent in relationships, acknowledging that the complainant, as a mature and well-placed woman, willingly engaged in the relationship without reporting any issues or abuse.
  • This judgment sets a strong precedent for cases involving false promise of marriage allegations, emphasizing that long-standing relationships based on mutual consent cannot be criminalized after a prolonged period, especially if the complainant had no objection to the relationship.
  • It could influence future cases where allegations are made after significant delays or if there is evidence of a long consensual relationship that later turns contentious.
  • This judgment might be challenged in cases where a complainant argues that they were coerced into consenting or were victims of emotional manipulation, especially in long-term relationships.
  • The legal community may examine how evidence of deception is weighed in cases of false promise of marriage where the relationship continued for years without objection from the complainant.
  • The Court underscored that a long-term consensual relationship cannot be classified as rape based on a false promise of marriage unless deceit is proven from the very beginning.
  • The judgment highlights the need for consistency in allegations and the timing of complaints in such sensitive cases.