Allegations of rape in cases of consensual relationships cannot be imposed solely due to a failed relationship.

Supreme Court Quashes Rape Charges in Consensual Relationship Case Court finds allegations based on failed relationship, stresses need for careful examination of consent in such cases

In a significant ruling, the Supreme Court of India quashed the First Information Report (FIR) and chargesheet against Samadhan, who faced allegations of rape under false promise of marriage. The judgment, delivered by Justices B.V. Nagarathna and R. Mahadevan, highlighted the need for careful assessment of allegations in cases involving consensual relationships.

The appellant, Samadhan, was initially charged under Sections 376, 376(2)(n), and 507 of the Indian Penal Code (IPC) based on allegations by the second respondent. The charges stemmed from a relationship that lasted over three years, during which the complainant claimed the appellant had engaged in a physical relationship on the false promise of marriage.

The Supreme Court noted that the relationship was consensual, with both parties voluntarily engaging in it. The court emphasized that physical intimacy occurring within the course of a functioning relationship cannot be retrospectively categorized as rape merely because the relationship failed to culminate in marriage. It further observed that allegations of rape under false promise of marriage must be scrutinized carefully, and criminal liability cannot be imposed solely due to the failure of a relationship.

The court also referenced previous judgments, including Mahesh Damu Khare v. State of Maharashtra and Prashant v. State of NCT of Delhi, which underscored the distinction between consensual relationships and cases where false promises are made with malicious intent.

The High Court of Bombay had earlier refused to quash the FIR, asserting that the matter warranted trial to ascertain the veracity of the allegations. However, the Supreme Court disagreed, stating that the High Court failed to appreciate that the relationship was consensual, and there was no evidence of coercion, fraud, or misrepresentation.

In conclusion, the Supreme Court allowed the appeal, setting aside the High Court's judgment, and quashed both the FIR and chargesheet against Samadhan. The court reiterated that the misuse of criminal law in cases of failed relationships must be condemned, as it inflicts undue stigma and injustice on the accused.

The judgment serves as a reminder of the importance of distinguishing between genuine cases of sexual violence and instances where a failed relationship is misrepresented as a criminal act. The court's decision underscores the necessity for the judiciary to exercise caution in such matters to prevent misuse of the legal system.

Bottom Line:

Allegations of rape under Section 376 IPC in cases of consensual relationships must be assessed carefully, and criminal liability cannot be imposed solely due to a failed relationship.

Statutory provision(s): Indian Penal Code, 1860 Sections 376, 376(2)(n), 507; Bharatiya Nagarik Suraksha Sanhita, 2023 Section 528

Samadhan v. State Of Maharasthra, (SC) : Law Finder Doc Id # 2812358