Title- Manish Yadav v. State of Uttar Pradesh & Anr. (Neutral Citation: 2025 INSC 151) Dated
Victim Indulged In Intimate Relations On Accord Of Her Own Desires, Not False Promise To Marry: SC Quashes Rape Case Against Accused
The Supreme Court has quashed the proceedings against a man who was accused of raping a woman on the pretext of false promise of marriage. The Court was dealing with Criminal Appeals preferred by the accused against the Order of the Allahabad High Court by which it upheld the Summoning Order issued against him. The two-Judge Bench of Justice Vikram Nath and Justice Sandeep Mehta observed, “… it is clearly discernible that in the present case, the complainant had agreed to indulge in intimate relations with the appellant on the accord of her own desires and not on the basis of any false promise of marriage made by the appellant. Therefore, while the present case may involve a breach of promise, it does not constitute a case of an inherently false promise to marry.” The Bench added that it cannot be concluded that the accused obtained the Complainant’s consent to engage in a physical relationship under the pretext of a false promise of marriage, based on the circumstances.
Factual Background As per the prosecution case, the Appellant-accused befriended the Complainant over a social media website namely Instagram, which quickly bloomed into a romantic relationship. The accused allegedly promised the Complainant that he would marry her and they would live together as husband and wife. It was alleged that under the pretence of the said promise of marriage, the accused established physical relations with the Complainant frequently at different places. It was further alleged that on account of the repeated physical relations, the Complainant conceived in 2022 and the accused forced her to undergo an abortion by taking medication.
Subsequently, the accused allegedly began assaulting her and used derogatory caste-based slurs, imputing that he would not marry her since he was a Yadav and she belonged to a lower caste. Hence, an FIR was registered against the accused under Sections 376, 313, 323, 504, and 506 of the Indian Penal Code (IPC) and Sections 3(1)(d) and 3(2)(va) of the Scheduled Castes and the Scheduled Tribes (Prevention of Atrocities) Act, 1989 (SC/ST Act). The Trial Court summoned the accused and his father which was partially affirmed by the High Court. The High Court had quashed the Summoning Order issued against the accused’s father but upheld the same against the accused. Hence, he was before the Apex Court.
The Supreme Court after hearing the contentions of the counsel, noted, “Admittedly, during his visit to Varanasi, the appellant himself had asked the complainant to elope with him and get married, but it was the complainant who insisted on waiting till he secured a job. Therefore, while the prosecution story primarily rests on the fact that the appellant had lured the complainant to develop physical relations with him on the promise to marry her in future, this very statement of the complainant suggests the contrary.” The Court said that the Complainant’s act of declining the Appellant’s proposal of marriage shows that it was not the Appellant who failed to stand firm upon his promise if any such promise was made by the Appellant at any point in time.
“Thus, the theory put forth by the prosecution in the chargesheet that the appellant induced the complainant to indulge in physical relations under a false promise of marriage is neither corroborated nor established by the best evidence available on record, which is in the form of the statement of the complainant recorded under Section 164 CrPC”, it added. Moreover, the Court noted that in her statement, the Complainant has not uttered a single word which shows that she was maligned or abused by the Appellant for belonging to a particular caste and therefore, the ingredients of the offences alleged under the SC/ST Act, against the Appellant are ex-facie not made out from the highest allegations as set out in the charge sheet. “… we are of the opinion that the present case appears to be one where a consensual physical relationship between two adults has turned sour due to certain intervening events. Hence, allowing the prosecution of the appellant for the offences mentioned above would tantamount to sheer abuse of the process of law and nothing else”, it concluded.
