False promise of marriage does not constitute rape unless the consent was obtained solely based on a deliberate deception; Long-term consensual relationships, even if they later fall apart, do not amount to rape: The Hon'ble Supreme Court

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Supreme Court Quashes Rape Case Over 16-Year Consensual Relationship – A Blow to Misuse of Law

Date of Judgment: 3 March 2025
Court: Supreme Court of India
Bench: Justice Vikram Nath and Justice Sandeep Mehta
Case: Rajnish Singh @ Soni vs. State of U.P. & Another
Citation: 2025 LiveLaw (SC) 279

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Background:

The complainant, a highly educated woman, lodged an FIR against the appellant under Sections 376, 384, 323, 504, 506 IPC, alleging rape based on a false promise of marriage after a 16-year-long relationship. She claimed the initial incident occurred in 2006 and that she remained silent due to blackmail involving obscene videos and continuous threats.

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Key Allegations:

• The appellant forcibly had intercourse with the complainant in 2006.

• He promised to marry her and continued the relationship.

• Allegedly drugged her, recorded intimate videos, and blackmailed her.

• Took money from her under threats.

• Eventually married another woman in 2022, triggering the complaint.

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Supreme Court Observations:

• The complainant was a major and highly educated woman living independently and meeting the appellant by choice.

• The relationship lasted 16 years without any legal action from the complainant, even though both were working professionals in different towns.

• Allegations of force, rape, or coercion were found to be contradictory and implausible.

• The complainant portrayed herself as the wife of the appellant in earlier legal documents.

• FIR was seen as a reaction to the appellant marrying someone else.

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Legal Principles Reaffirmed:

• False promise of marriage does not constitute rape unless the consent was obtained solely based on a deliberate deception.

• Long-term consensual relationships, even if they later fall apart, do not amount to rape.

• Courts must differentiate between breach of promise and false promise with mala fide intent (Deepak Gulati case).

• The prolonged silence and continued intimacy disproved any coercion (Mahesh Damu Khare, Prashant, Shivashankar precedents applied).

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Verdict:

• The Supreme Court held the case to be a misuse of criminal law.

• FIR and all subsequent proceedings were quashed.

• Termed it a “love affair/live-in relationship gone sour.”

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Conclusion:

This judgment reinforces that criminal law cannot be weaponized in failed relationships. Consent given in long-term associations, even if the promise of marriage remains unfulfilled, cannot be retrospectively painted as rape, unless mala fide intent is proved from the start.

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