In a rare exercise of its powers under Article 142, the Supreme Court set aside a conviction for rape on alleged false promise of marriage where the complainant and accused later married and reside together.
Supreme Court of India | Bench & Date of Judgment
A Bench of Justices B.V. Nagarathna and Satish Chandra Sharma of the Supreme Court of India delivered the judgment on 5 December 2025.
Case Title
State of Madhya Pradesh v. Sandeep Singh Thakur (2025), connected with an appeal against a rape conviction.
Background and Key Legal Issue
The case stemmed from a 2015 consensual relationship between a man and a woman which turned physical. According to the woman’s complaint, she consented to the relationship based on the accused’s promise to marry her. When the marriage did not materialise within her expectations, she filed a First Information Report (FIR) in November 2021 at a women’s police station in Sagar district, Madhya Pradesh, alleging repeated rape on the basis of a false promise of marriage.
A trial court convicted the accused in April 2024, sentencing him to ten years’ imprisonment for rape under Sections 376(2)(n) of the Indian Penal Code and two years for cheating under Section 417 of the IPC, along with fines.
The key legal issue before the Supreme Court was whether the conviction for rape, based on an alleged false promise of marriage, could stand where subsequent developments indicated that the parties had married and were cohabiting, challenging the premise of deceit.
Proceedings in the Supreme Court
The matter initially reached the Supreme Court as an appeal challenging the Madhya Pradesh High Court’s refusal to suspend the sentence. During hearings, the Bench observed that the relationship might be consensual and capable of resolution outside the criminal process. Acting on what the judges described as a “sixth sense” that the parties could be brought together, the Bench suggested that counsel obtain instructions regarding marriage.
On 15 May 2025, both the accused and the woman appeared with their parents before the Court. After private discussions, they expressed willingness to marry. The Bench granted interim bail, facilitating the ceremony. By 22 July 2025, the couple had married and were living together.
Final Ruling
On 5 December 2025, the Supreme Court, invoking its extraordinary powers under Article 142 of the Constitution, quashed the FIR, the trial court’s conviction and sentence, and rendered the pending appeal before the High Court infructuous.
The Bench also directed that the accused’s suspension from government service be revoked and that he be paid arrears of salary, noting that he had already rejoined duty under interim orders.
Reasoning of the Court
The Court recorded that its intervention facilitated the marriage of the parties and that the complainant, now the accused’s wife, no longer wished to pursue the criminal proceedings. It observed that the criminal complaint may have arisen from insecurity caused by postponement of marriage, rather than from deliberate deception.
The Bench held that the consensual nature of the relationship was given a criminal colour due to a misunderstanding, and that, in the circumstances, there was no clear evidence that the accused had the requisite deceptive intent necessary to sustain a conviction for rape based on a false promise of marriage.
The Court’s decision rested on the broader context of the parties’ subsequent marriage and continued cohabitation, as well as the complainant’s expressed desire to withdraw the case.
Practical Implications
The judgment highlights the limited scope of criminal law in disputes involving failed personal relationships where consent is later affirmed by marriage and joint decision-making.
It underscores the use of Article 142 powers by the Supreme Court to achieve complete justice in exceptional circumstances, including quashing criminal proceedings where continuation serves no public interest.
The order may influence how courts view rape allegations based on promises of marriage, particularly where evidence of deceit is ambiguous and the parties reconcile.
The judgment could prompt stakeholders to reflect on the interface between consent, personal relationships and criminal law in cases involving allegations of exploitation.
The judgment adds clarity on the circumstances under which criminal proceedings based on alleged false promises of marriage may be quashed when subsequent developments, including marriage and mutual consent, indicate that the initial dispute arose from misunderstanding rather than deliberate deception.
