Introduction
The Supreme Court of India recently delivered a rare and highly publicized judgment quashing a rape conviction that arose from an alleged false promise of marriage. The Court used its extraordinary powers under Article 142 of the Constitution to not only overturn the conviction and sentence against the man but also to facilitate a marriage between the parties. The decision has attracted wide legal attention because the judges openly acknowledged acting on a “sixth sense” to resolve the dispute and restore justice.
Facts of the Case
At the heart of the case was a prolonged relationship between a man and a woman that began in 2015 through social media. The couple developed mutual affection and later entered into a physical relationship, which the woman said was based on the man’s promise to marry her. When marriage did not happen within the expected time, she filed a criminal complaint in November 2021, alleging that he had induced her into the relationship with a false promise of marriage and then betrayed her trust.
The local trial court found the man guilty of repeated rape and cheating under Sections 376 and 376(2)(n) of the Indian Penal Code. He received a ten-year term for rape and a two-year sentence for cheating. His conviction was later appealed to the Madhya Pradesh High Court, which refused to suspend the sentence pending appeal. The man then moved the Supreme Court, arguing that his conviction was unsustainable and that he should be granted relief.
Supreme Court Ruling
When the matter reached the Supreme Court, a Bench led by Justices B.V. Nagarathna and Satish Chandra Sharma carefully examined the case record. The bench noted a crucial fact: by the time the Supreme Court was hearing the appeal, the man and the woman were willing to marry each other. On an instinctive assessment of the facts, the judges suggested that counsel for both sides obtain instructions from the parties. The Court later met privately with both individuals and their parents in chambers. The interaction revealed that they were willing to solemnize their marriage, which led the Court to grant interim bail to the appellant. The couple married on July 22, 2025, and has been living together since.
In its final ruling, the Supreme Court quashed the First Information Report, the conviction, and the sentence. The Bench acknowledged that this was one of the rarest of rare cases where judicial intervention actually resolved the underlying dispute between the parties. The Court described the case as one in which a consensual relationship was wrongly given a criminal colour after it had turned sour. It held that the original criminal complaint may have stemmed from emotional volatility and insecurity when the appellant sought to postpone the marriage date, rather than from a genuine intention to commit a crime.
The Court emphasized that the relationship’s consensual nature undercuts the basis for rape charges where consent was not shown to have been obtained by force, fraud, or deception from the start. Because the parties ultimately chose to marry and the woman expressly stated that she no longer wished to pursue the criminal proceedings, the Bench held that continuing the prosecution would not serve justice.
The Supreme Court also addressed collateral issues arising from the case. It directed the authorities in Madhya Pradesh to restore the appellant’s government service, revoke his suspension, and ensure that all arrears of salary were paid within two months. This step underscored the Court’s intent to make the party whole after quashing the conviction. With the appeal disposed of as infructuous, the judgment effectively closed the criminal chapter of the dispute.
Implications
Legal commentators say the judgment highlights evolving jurisprudence around consent, promise of marriage, and criminal law in India. The Court reaffirmed a long-standing principle: a mere breach of a promise to marry does not automatically constitute rape unless it is shown that the promise was false from the very beginning and that consent was procured by fraud. Courts have previously held that consensual relationships, even when based on an expectation of marriage, do not automatically trigger criminal liability without clear evidence of fraudulent intent.
This judgment may influence how future cases involving allegations of sexual exploitation under the pretext of marriage are handled. It signals judicial caution against criminalizing consensual relationships that later go awry and underscores the importance of evaluating each case on its own facts rather than assuming malicious intent where none clearly appears. The decision also illustrates the Supreme Court’s willingness to invoke Article 142 to provide complete justice in exceptional circumstances.
