The Supreme Court quashed a rape case, ruling it as a misuse of legal provisions arising from a failed 16-year relationship.
BRIEF FACTS
The complainant alleged that the appellant first established physical relations with her in 2006 and continued the relationship by coercing her through threats and blackmail. She further claimed that the appellant had recorded intimate videos and used them to manipulate and exploit her over the years.
The complainant stated that she refrained from reporting the matter earlier due to fear of social repercussions. However, in 2022, after discovering that the appellant had married another woman, she lodged a complaint, accusing him of rape (Section 376 IPC), extortion (Section 384 IPC), voluntarily causing hurt (Section 323 IPC), intentional insult (Section 504 IPC), and criminal intimidation (Section 506 IPC).
Court’s Reasoning and Observations
A Supreme Court Bench comprising Justice Vikram Nath and Justice Sandeep Mehta ruled in favor of the appellant, holding that the long-standing nature of the relationship made it difficult to accept that it was based on coercion or deceit.
Referring to legal precedents, the Court stated:
“Testing the facts of the case at hand, on the touchstone of the above precedents, it is clear that the complainant, being a highly qualified major woman, continued in a consensual intimate sexual relationship with the appellant over a period of 16 years. At some point in time, the relationship went sour, leading to the filing of the FIR. No reasonable man would accept the version that the complainant allowed the accused to establish sexual relations with her over a period of 16 years purely under the misconception of marriage.”
Key Factors Considered by the Court
- Portrayal as Appellant’s Wife
- The complainant, on multiple occasions, represented herself as the wife of the appellant, dispelling the claim that the appellant’s intent was fraudulent from the outset.
- Frequent Travel to Meet the Appellant
- The Court noted that the complainant regularly traveled to meet the appellant at his place of posting, reinforcing the conclusion that the relationship was voluntary and consensual.
- Alleged Secret Marriage
- The complainant herself claimed that a secret marriage ceremony had taken place between her and the appellant.
- The Court observed that, even if this allegation was taken at face value, it indicated a long-standing live-in relationship rather than an instance of sexual exploitation under false assurances of marriage.
- Complaint Filed Only After Appellant’s Marriage
- The FIR was registered only after the complainant discovered that the appellant was marrying another woman.
- The Court pointed out that her primary intent behind filing the complaint was to stop the appellant’s marriage.
Supreme Court’s Verdict
The Court cited its ruling in Mahesh Damu Khare v. State of Maharashtra, which held:
“In a situation where the woman knowingly maintains the physical relationship for a prolonged period, it cannot be said with certainty that the said physical relationship was purely because of an alleged promise made by the accused to marry her.”
In its final remarks, the Bench stated:
“It is almost impossible to swallow the version of the complainant that for the entire period of 16 years, she unreservedly allowed the appellant to subject her to repeated acts of sexual intercourse under the impression that the accused would someday act upon his promise of marriage.”
Accordingly, the order of the Allahabad High Court was quashed, and as a consequence, FIR No. 269 of 2022 and all related proceedings against the appellant were set aside.
Complainant’s Allegations
The complainant alleged that the accused raped her in 2006 inside her own house, but she did not report the incident at the time because he had assured her of marriage. She further claimed that in 2009, the accused drugged her and recorded their intimate moments without her consent, using the videos as leverage to exploit her.
Additionally, she accused the man of forcing her to undergo an abortion and extorting money from her by threatening to make the recorded videos public.
The complainant finally approached the police in 2022, when she learned that the accused was marrying another woman.
Accused’s Defense and State’s Argument
Seeking quashing of the case, the accused argued that the relationship was purely consensual and that there was no deception involved.
However, the State and the complainant opposed the plea, maintaining that the accused had misled her with a false promise of marriage and exploited her sexually and financially over the years.
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Supreme Court’s Key Observations
Doubts Over Allegation of Rape in 2006
The Supreme Court outrightly dismissed the complainant’s claim that she was raped inside her own house in 2006 while her parents were present. The Bench found this version of events highly questionable.
“It needs to be highlighted that the complainant categorically stated in the FIR that the first act of sexual relation took place in her own house, where her parents were also present. The very manner in which this incident is said to have taken place puts the case of the complainant under serious doubt.”
Rejection of ‘Intoxication and Videography’ Allegation
The Court also expressed skepticism over the complainant’s claim that, after maintaining a consensual relationship for over three years, the accused spiked her drink in 2009 to record intimate moments.
“It does not stand to reason that when the intimate relations were continuing between the parties without any hitch for more than three years, then why would the appellant be impelled to take the trouble of spiking the drink of the complainant in order to establish sexual relations with her.”
No Evidence of Coercion or False Promise of Marriage
The Supreme Court noted that:
“Both the accused and the complainant lived in different towns, and their interactions were based on mutual convenience. There was no force, intimidation, or continued pressure that would have prevented the complainant from filing a complaint earlier”
Additionally, the Bench pointed out that the complainant had, on multiple occasions, portrayed herself as the accused’s wife, further weakening the claim that he had cheated her with false promises.
“We cannot remain oblivious to the fact that it was mostly the complainant who used to travel to meet the appellant at his place of posting. Therefore, we are convinced that the relationship between the complainant and appellant was consensual without the existence of any element of deceit or misconception.”
Delayed Complaint Raises Suspicions
The 16-year delay between the alleged first act of sexual intercourse and the filing of the FIR in 2022 was another major factor in the Court’s decision. The Bench observed that the complainant approached the police only after discovering that the accused was marrying someone else, which indicated that the case was motivated by personal grievances rather than any actual criminal offense.
“The long gap of 16 years between the first act of sexual intercourse and the filing of the FIR convinces us that it is a clear case of a love affair gone sour.”
Final Verdict
The Court firmly rejected the complainant’s allegations as contradictory and lacking credibility, ruling that the accused could not be prosecuted for sexual exploitation based on a false promise of marriage.
“By no stretch of imagination can this Court be convinced that the present case involves sexual exploitation or assault based on a false promise of marriage. The allegations are full of material contradictions and are ex facie unbelievable.”
Accordingly, the Supreme Court quashed the FIR and all subsequent legal proceedings against the accused.
CASE TITLE: Rajnish Singh @ Soni v. State of U.P. & Anr.
Neutral Citation: 2025 INSC 308
Appearance:
Appellant: Advocates Pradeep Kumar Yadav, Anjale Kumari, Gopal Singh, Vishal Thakre, Sunil Kumar Srivastava, Ashwani Garg and Tota Ram; AOR Sanjeev Malhotra
Respondent: Advocates Vikas Bansal, Harshit Singhal, Nitin Meshram, Saurabh Singh, Rishi Raj Singh; AOR Ankit Goel and Ranbir Singh Yadav
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