Saurabh Pal Singh v. State of U.P. & Another, 2026

The informant, a Scheduled Caste woman pursuing a PhD, alleged that the accused established physical relations with her on a promise of marriage.

She alleged that the relationship continued for several years and that the accused subsequently refused to marry her.

She also alleged that the accused obtained money, her ATM card and other property in connection with a proposed restaurant business.

Two cheques allegedly issued towards repayment were stated to have been dishonoured.

An FIR was registered alleging offences including rape, cheating and criminal breach of trust, along with an offence under the SC/ST Act.

The accused sought discharge under Section 227 CrPC, but the trial court rejected the application and subsequently framed charges.

The accused approached the High Court challenging the refusal of discharge and framing of charges.

The High Court allowed the connected criminal appeals.

The orders rejecting the discharge application and framing charges were set aside.

The accused was discharged from the offences under Sections 376, 406, 420, 504 and 506 IPC and Section 3(2)(v) of the SC/ST Act.

The Court found that the record did not establish, even prima facie, that the alleged promise of marriage was false from the very beginning and made in bad faith.

The Court noted the long duration of the physical relationship and the informant's statement that there was no romantic relationship between them.

The allegations concerning ₹15 lakh were connected to a business transaction, making the dispute predominantly civil and financial in character.

The Court also found insufficient material to establish criminal breach of trust or caste-based criminal intent.

The judgment reinforces the distinction between a false promise to marry and a subsequent failure to marry. The critical question is the accused's intention at the inception of the relationship.

The Court relied upon the circumstances surrounding the relationship, particularly its long duration, while assessing whether consent was allegedly obtained through deception.

Importantly, the Court did not treat every relationship that ends without marriage as a criminal offence. Such an approach would risk converting failed personal relationships into criminal prosecutions without satisfying the ingredients of Section 376 IPC.

On the financial allegations, the Court separated civil liability from criminal culpability. A dispute involving money advanced for a business venture does not automatically amount to cheating or criminal breach of trust.

The Court also highlighted the conceptual distinction between Section 406 and Section 420 IPC. Criminal breach of trust centres on entrustment followed by dishonest misappropriation, whereas cheating requires deceptive or dishonest intention at the time of inducement. 

The SC/ST Act allegation was also subjected to the statutory requirement of a caste-based connection. The victim's Scheduled Caste status alone was insufficient.

The decision demonstrates the importance of the discharge stage. Although the court does not conduct a full trial at this stage, it must still examine whether the prosecution material creates the legally required prima facie case or grave suspicion.

Overall, the judgment prevents criminal law from being used to settle what the Court considered a predominantly civil, commercial and interpersonal dispute, while preserving the principle that genuinely deceptive promises made from inception can attract criminal liability.