The Supreme Court has quashed criminal proceedings against a man accused of sexual exploitation on an alleged promise of marriage. In the False Promise Marriage Case, the Court found no evidence that coercion or misrepresentation caused the woman to consent. The relationship had continued consensually for about three years before the parties separated.
A Bench comprising Justice JB Pardiwala and Justice K Vinod Chandran allowed the appeal against the Chhattisgarh government and the complainant. The Court noted that the criminal complaint followed the breakdown of a long-term relationship.
FIR Filed After Relationship Ended
The complainant registered an FIR in 2025. She alleged that the appellant sexually exploited her on the pretext of marriage and later refused to marry her.
Police subsequently filed a chargesheet. The accused then approached the Supreme Court through a Special Leave Petition (SLP) and sought relief against the criminal proceedings.
Supreme Court Relies on Deepak Gulati Judgment
The Supreme Court reiterated the principles laid down in Deepak Gulati v. State of Haryana.
The Court explained that the prosecution must show that the accused never intended to honour the promise to marry from the beginning. A relationship does not become criminal merely because a person later fails to fulfil a promise about marriage.
The Bench also examined Section 90 of the Indian Penal Code, 1860 (IPC). The corresponding provision now appears in Section 28 of the Bharatiya Nyaya Sanhita, 2023 (BNS).
The Court said these provisions cannot impose criminal liability without evidence of fraudulent intent from the outset.
Court Examines Three-Year Relationship
The Bench considered the complainant’s background and the circumstances surrounding the relationship.
The complainant was an engineering graduate who was preparing for competitive examinations. She met the appellant at an academy where both studied.
They subsequently entered into a relationship. Their respective families also communicated with each other.
The appellant visited the complainant at the residence where she lived with her mother and brother. Their physical relationship began when nobody else was present at the house. It continued for about three years.
Court Examines Visits to Complainant’s Home
The complainant alleged that the appellant frequently visited her when her mother was away.
However, the Court rejected the suggestion that he constantly monitored the residence to know when her mother left.
The Bench observed that the complainant herself had “obviously” informed him when her mother was away. It found no basis to presume that the appellant kept the residence under constant surveillance.
The relationship continued without interruption for three years before the parties eventually separated.
Marriage Proposal Between Families Fails
The Court also considered the marriage discussions between the two families. Those discussions ultimately did not result in marriage.
The complainant lodged the criminal complaint after the relationship ended.
She also claimed that the appellant agreed to marry her before the Mahila Thana Counselling Centre in Bilaspur. However, he later failed to honour the undertaking.
The Supreme Court did not accept this undertaking as proof of an earlier false promise. It noted that the threat of criminal prosecution could have prompted the undertaking. The Court also said such an undertaking would not be enforceable.
By that stage, the parties had already maintained a three-year relationship. The complainant had admittedly consented to the physical relationship during this period.
Consent Cannot Be Presumed to Be Vitiated
The Supreme Court reiterated that courts should not casually infer fear or misconception when examining consent.
The Bench found no specific or clear assurance of marriage in the complaint. Instead, the circumstances indicated that the parties entered into a physical relationship during their courtship.
The Court noted that both parties understood the consequences of their relationship. The later claim that a promise of marriage formed the basis of the relationship appeared as an afterthought to the Court.
Therefore, the Bench found no basis to conclude that coercion or misrepresentation had vitiated the complainant’s consent.
Criminal Case Cannot Become a Strong-Arm Tactic
The Court also considered the complainant’s educational background and the duration of the relationship.
It noted that she was a well-educated woman who had voluntarily continued the relationship for three years. Although she allegedly expected the relationship to lead to marriage, the marriage ultimately did not materialise.
The complainant had also stated that she would withdraw the criminal allegations if the appellant married her.
Against this background, the Supreme Court said:
“A criminal prosecution cannot be reduced to a strong-arm tactic.”
The Court stressed that the breakdown of a relationship cannot, by itself, establish criminal culpability.
Supreme Court Quashes Criminal Proceedings
After examining the circumstances, the Supreme Court found no criminal culpability arising from the appellant’s consensual relationship with the complainant.
The ruling in the False Promise Marriage Case reinforces the distinction between a deliberately fraudulent promise made at the outset and a genuine relationship that later fails.
Accordingly, the Bench quashed the criminal proceedings against the appellant and allowed the appeal.
