Article 142 Invoked to Ensure Justice as Parties Marry, Criminal Proceedings Nullified
In a significant judgment delivered on December 5, 2025, the Supreme Court of India, led by Justices B.V. Nagarathna and Satish Chandra Sharma, quashed the conviction and sentence against Sandeep Singh Thakur under Sections 376(2)(n) and 417 of the Indian Penal Code (IPC). The Court emphasized the consensual nature of the relationship between Thakur and the prosecutrix, which subsequently led to their marriage, thereby invoking Article 142 of the Constitution to ensure complete justice.
The appellant, Sandeep Singh Thakur, had been previously convicted by the Additional Sessions Judge under charges of rape and cheating, resulting in a rigorous imprisonment sentence of ten years and a fine. The case, initially filed as FIR No.29 of 2021 on November 2, 2021, was based on allegations of false promise of marriage. However, upon appeal, the Supreme Court recognized the consensual nature of the relationship and noted that the misunderstanding between the parties led to the criminal complaint.
In an extraordinary intervention, the Supreme Court facilitated discussions between the appellant and the prosecutrix, leading to their marriage on July 22, 2025. The judgment highlighted the Court's role in bringing the parties together, emphasizing that the appellant's postponement of marriage might have caused insecurity, leading to the filing of the complaint. The Supreme Court's decision to quash the proceedings reflects a nuanced understanding of personal relationships and the misuse of criminal law in such contexts.
Furthermore, the Court directed the revocation of Thakur's suspension from government service, ensuring the payment of arrears within two months. The judgment serves as a precedent in handling similar cases, showcasing the Court's commitment to justice beyond mere legal frameworks.
Bottom Line:
The Supreme Court quashed the conviction and sentence under Sections 376(2)(n) and 417 IPC, emphasizing the consensual nature of the relationship, subsequent marriage between the parties, and invoked Article 142 of the Constitution to ensure complete justice.
Statutory provision(s): Sections 376(2)(n) and 417 IPC, Article 142 of the Constitution of India
Sandeep Singh Thakur v. State of Madhya Pradesh, (SC) : Law Finder Doc Id # 2826682
