Court’s Decision:
The Supreme Court quashed the FIR and all legal proceedings against the appellant. It ruled that the case did not constitute rape as the relationship was consensual and spanned 16 years. The Court found no evidence of coercion or false inducement from the beginning and deemed the legal action an abuse of process.
Facts of the Case:
- The complainant lodged an FIR in 2022, alleging that the appellant had sexually exploited her since 2006 under a false promise of marriage.
- The first incident allegedly occurred at her house, where she was unable to scream for help.
- The relationship continued for several years, with repeated sexual encounters.
- The appellant allegedly spiked the complainant’s drink, recorded intimate videos, and later used them to blackmail her.
- The complainant claimed that she lent Rs. 94,000 to the appellant, which was never repaid.
- Their relationship continued until 2021, when the appellant married another woman, prompting the complainant to file the FIR.
Issues Before the Court:
- Does a long-term consensual relationship qualify as sexual exploitation under a false promise of marriage?
- Is the complainant’s delay of 16 years in filing the FIR credible?
- Does allowing prosecution violate the legal principle against abuse of process?
Petitioner’s (Appellant’s) Arguments:
- The relationship was entirely consensual and lasted for 16 years, meaning coercion or false inducement was improbable.
- The complainant was an educated adult and fully aware of her choices.
- The complainant herself identified as the appellant’s wife in previous legal proceedings, contradicting the claim that she was deceived.
- The timing of the FIR—filed only after the appellant married another woman—indicated a motive of vengeance rather than justice.
Respondent’s (Complainant’s) Arguments:
- The appellant manipulated and sexually exploited the complainant under the pretext of marriage.
- The appellant blackmailed her with intimate videos to ensure compliance.
- The complainant remained silent due to fear, stigma, and continued threats.
- The delay in filing the FIR was due to emotional trauma, not an afterthought.
Analysis of the Law:
The Court analyzed Indian Penal Code (IPC) Sections 376 (rape) and 90 (consent under misconception of fact) to determine if the case constituted rape under a false promise of marriage.
- Key legal principle: If a person enters a relationship knowingly and voluntarily, the failure to marry later does not constitute rape, unless deception existed from the beginning.
Precedent Analysis:
The Court relied on several Supreme Court precedents to clarify the law:
- Mahesh Damu Khare v. State of Maharashtra (2024 SCC OnLine SC 3471)
- Held that prolonged consensual relationships cannot be reinterpreted as rape simply because marriage did not happen.
- Prashant v. State (NCT of Delhi) (2024 SCC OnLine SC 3375)
- Stated that if a woman continues a relationship for years, she cannot later claim that all encounters were coerced.
- Deepak Gulati v. State of Haryana (2013) 7 SCC 675
- Differentiated between a false promise and an unfulfilled promise. A promise that fails due to circumstances beyond control is not fraud.
- Shivashankar v. State of Karnataka (2019) 18 SCC 204
- Quashed an FIR where the relationship lasted eight years, reasoning that it was consensual throughout.
Court’s Reasoning:
- Long Duration Weakens the Claim of Coercion
- The complainant voluntarily continued the relationship for 16 years, making it unlikely that she was misled the entire time.
- Educated and Independent Complainant
- The complainant was well-qualified and held a professional job, contradicting the claim that she was easily manipulated.
- Unexplained Delay in Filing the FIR
- The Court found no logical reason for waiting 16 years to report alleged sexual abuse.
- No Proof of Initial Deception
- The complainant had identified herself as the appellant’s wife, proving that she did not see herself as a victim at the time.
- Misuse of Rape Laws
- The case was an example of using sexual offence laws to settle personal scores.
Conclusion:
- The Supreme Court found no evidence of coercion or deception from the beginning of the relationship.
- The FIR and entire criminal case were quashed, preventing misuse of rape laws in failed relationships.
Implications of the Judgment:
1. Clarifies Consent vs. False Promise of Marriage
- The ruling reinforces that consent given in a long-term relationship cannot later be withdrawn on the basis of non-marriage.
2. Prevents Misuse of Rape Laws
- The judgment protects genuine rape victims by preventing false cases that dilute the seriousness of sexual offences.
3. Legal Precedent for Future Cases
- This decision sets a strong precedent for future cases involving delayed allegations of sexual exploitation in failed relationships.