Supreme Court Quashes Rape Allegations Based on False Promise of Marriage Apex Court rules no case of rape where complainant aware of legal bar to marriage due to existing matrimonial status.
In a pivotal judgment, the Supreme Court of India has quashed an FIR and subsequent proceedings in a case involving allegations of rape based on a false promise of marriage. The bench, comprising Justices B.V. Nagarathna and Ujjal Bhuyan, delivered the verdict in the case of Pramod Kumar Navratna v. State of Chhattisgarh, emphasizing that allegations of rape on a false pretext of marriage do not constitute the offence under Section 376(2)(n) of the Indian Penal Code (IPC) when the complainant is aware of the legal impossibility of such a marriage.
The case arose from an FIR filed by a married woman advocate who alleged that she was raped under the false promise of marriage by the appellant, also an advocate. The complainant, despite knowing her own marital status, claimed that the appellant induced her into a sexual relationship under the guise of marriage.
The Supreme Court highlighted that the complainant, being an advocate, was fully aware of her marital status and the legal bar to marrying the appellant. The court reiterated that in cases where the complainant is aware of such legal impediments, allegations of inducement to sexual relations under the pretext of marriage cannot be sustained under Section 376(2)(n) IPC.
Furthermore, the court expressed concern over the misuse of Section 376 IPC, noting that such frivolous allegations burden the judicial system and trivialize the seriousness of genuine rape cases. The court cited the importance of differentiating between failed consensual relationships and cases of genuine sexual violence.
The judgment also reiterated the principle that criminal proceedings for rape cannot be initiated in consensual relationships unless it is clearly established that the promise of marriage was false from the very beginning and intended to deceive. In this case, the court found no evidence to suggest that the appellant made a false promise of marriage with the intent to deceive, especially given the complainant’s awareness of her existing marital ties.
The court’s decision underscores the need for careful scrutiny in cases involving allegations of rape on the false pretext of marriage, particularly when the complainant is aware of circumstances that legally bar the fulfilment of such promises. The ruling is expected to have significant implications for similar cases, reaffirming the judiciary's commitment to preventing the misuse of rape laws while ensuring justice for genuine victims.
Bottom Line:
The Supreme Court held that allegations of rape on the false pretext of marriage, in cases where the complainant is aware of the legal bar to such marriage (e.g., being already married), do not constitute the offence of rape under Section 376(2)(n) IPC.
Statutory provision(s):
- Indian Penal Code, 1860, Section 376(2)(n)
- Bharatiya Nagarik Suraksha Sanhita, Section 482
Pramod Kumar Navratna v. State of Chhattisgarh, (SC) : Law Finder Doc Id # 2849402
