Court Quashes Rape Allegation Based on False Promise of Marriage
The Supreme Court quashed an FIR against a man accused of rape based on a false promise of marriage. The Court ruled that a long-term live-in relationship implies valid consent and not deceit.
Live-In Relationship Indicates Mutual Consent
The bench, comprising Justices Sanjay Karol and Manoj Misra, noted that the couple had lived together for over two years. During this time, there was no prior complaint of coercion or lack of consent. The FIR alleged that the man had forcible sex with the woman on November 18, 2023. Yet, just a day later, on November 19, they executed a settlement deed affirming mutual love and intent to marry.
The FIR was lodged on November 23, 2023. The Uttarakhand High Court had earlier refused to quash it, prompting the man to appeal to the Supreme Court.
Court Finds Allegations Unconvincing
The Supreme Court observed that there was no claim in the FIR suggesting that physical intimacy occurred solely because of a marriage promise. The Court said, “The physical relationship lasted over two years without any complaint. That supports the presumption of valid consent.”
It held that when adults cohabit as a couple for years, their decision reflects a conscious, voluntary choice. Hence, the claim that the relationship was based on a false promise of marriage was deemed “unworthy of acceptance.”
Expression of Intent to Marry Doesn’t Equal Deception
The Court clarified that a mutual desire to marry, expressed during the relationship, doesn’t automatically prove deception. “Even if a couple wishes to formalize the relationship later, that wish alone doesn’t imply the relationship started based on a false promise,” the bench said.
Financial Independence Driving Rise in Live-In Relationships
The Court acknowledged a shift in social norms. “Earlier, live-in relationships were rare. But with more financially independent women, these relationships have become common,” the Court stated. It stressed that courts should avoid a rigid view and assess such cases based on relationship length and mutual conduct.
Final Verdict: FIR Quashed as Abuse of Process
The Court ruled that the couple’s extended live-in relationship in a rented home signaled valid consent. Continuing the criminal case would, therefore, amount to misuse of legal proceedings.
The appeal was allowed, and the FIR was quashed.
