Supreme Court Quashes Rape Case, Reiterates Position on Consent and False Promise of Marriage

The Supreme Court of India has quashed a rape case filed against Biswa Jyoti Chatterjee, a former judicial officer, after he was accused of raping a woman under the false promise of marriage. The Court reiterated its stance that a breach of promise to marry does not automatically constitute rape, unless it is proven that the woman's consent was obtained through fraud from the very beginning.

A bench comprising Justices BV Nagarathna and Satish Chandra Sharma emphasized that the complainant, a mature woman (36 years old), had voluntarily entered into a consensual sexual relationship with the accused, continuing for over a year, with full knowledge of the circumstances surrounding the appellant’s marital status. The Court held that the criminal proceedings against the former judicial officer amounted to an abuse of process of law, citing a growing trend of criminal complaints being filed when relationships turn sour.

Case Background:

The complainant was involved in an ongoing divorce case in 2014, in which the appellant was the presiding officer. During this time, the two grew close and eventually entered into a sexual relationship, based on the appellant's promise to marry her once her divorce was finalized. However, after the complainant's divorce was granted, the appellant allegedly cut off contact with her, leading to the filing of an FIR under sections 376(2)(f) (rape by deceit), 417 (cheating), and 506 (criminal intimidation).

After the Sessions Court and High Court rejected his discharge application, the appellant appealed to the Supreme Court.

Supreme Court’s Judgment:

The Court found that the prosecution failed to establish that the appellant had fraudulently promised marriage without any intention of marrying the complainant. The bench observed that the complainant had consented to the sexual relationship with the knowledge that the appellant was separated but not divorced at the time. The Court made it clear that the complainant could not claim rape based on the false pretext of marriage, especially since she was aware of the appellant’s marital situation from the beginning.

The Court highlighted that even if the complainant’s version of events were accepted, it was inconceivable that she would continue to maintain a sexual relationship with the appellant if she believed her consent had been vitiated by fraud. The Court emphasized that consent could not be said to be absent, especially after a prolonged relationship of more than a year.

Key Observations by the Court:

• Consent and Knowledge of Circumstances: The complainant knew that the appellant was still married (though separated) and made an informed decision to maintain the relationship.
• False Promise of Marriage Not Enough for Rape: A promise to marry, even if unfulfilled, does not necessarily lead to rape unless fraudulent intent can be proven from the outset.
• Abuse of Legal Process: The Court noted that the growing trend of criminalizing breakups in consensual relationships was problematic, as relationships that turn sour cannot automatically lead to criminal liability for rape.
• Voluntary Relationship: The complainant’s continued association and physical relationship with the appellant indicated voluntary consent, and the case did not meet the legal threshold for rape based on a false promise.

Court's Conclusion:

The Supreme Court quashed the criminal proceedings against the former judicial officer, acknowledging that the relationship between the complainant and the appellant was consensual. The Court stated that the initiation of the rape charge was an abuse of the legal process, as the complainant's allegations, even if taken at face value, did not establish that the physical relationship was based on deceit.

Legal Implications:

This judgment serves as a critical reminder that false promises of marriage, though potentially morally questionable, do not automatically translate to rape under Indian law unless it is demonstrated that consent was obtained fraudulently from the beginning. The ruling further underscores the importance of protecting individuals from frivolous legal claims based on relationships that are consensual, even if they end without marriage.

Case Title: Biswa Jyoti Chatterjee v. State of West Bengal & Anr., 2025