The Supreme Court warned against turning failed relationships into rape cases, calling it a worrying misuse of criminal law. It said consensual intimacy in a genuine relationship cannot later be labelled as rape just because marriage did not happen.
New Delhi: The Supreme Court has strongly expressed concern over the growing trend where broken or failed relationships are being wrongly given the colour of serious criminal offences like rape. The Court said such misuse of the criminal justice system is deeply worrying and must be condemned.
While quashing an FIR in an alleged rape case, the apex court made it clear that turning every failed relationship into a rape allegation not only weakens the seriousness of the crime but also causes irreversible damage to the reputation and life of the accused.
A bench comprising Justices B V Nagarathna and R Mahadevan observed that the offence of rape must only be applied in situations where there is genuine sexual violence, coercion, or absence of free consent.
The judges emphasized that consensual physical relations during a functioning relationship cannot later be labelled as rape simply because the relationship did not result in marriage.
However, the Court also stressed that genuine cases where trust is broken and dignity is harmed must still receive proper legal protection.
“This court has, on numerous occasions, taken note of the disquieting tendency wherein failed or broken relationships are given the colour of criminality,”
the bench stated while explaining its concern over such legal misuse.
The Supreme Court delivered this verdict while hearing an appeal filed by a man who challenged a March 2025 order of the Bombay High Court at Aurangabad.
The High Court had earlier dismissed his plea seeking quashing of an FIR registered in August 2024 in Chhatrapati Sambhajinagar city, where he was accused of rape on the false promise of marriage.
The apex court carefully examined the facts and noted that the entire allegation was based on the woman’s claim that the man had physical relations with her by promising marriage.
The court found this argument weak, stating,
“We find that the present case is not a case where the appellant (man) lured respondent no. 2 (woman) solely for physical pleasures and then vanished. The relationship continued for a period of three long years, which is a considerable period of time,”
highlighting that the relationship was neither casual nor deceptive from the beginning.
The bench further clarified that physical intimacy that takes place in a voluntary relationship cannot later be treated as rape just because the relationship ended. It observed that such an approach would lead to unfair criminalisation of personal disputes and serious injustice to the accused.
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The judges also acknowledged the importance of marriage in Indian society and recognised that emotional expectations often arise from intimate relationships. Still, the law must draw a clear line between genuine criminal conduct and personal disappointment.
The Court reminded that while protecting women from genuine sexual exploitation is essential, the law should not be used as a tool for revenge or pressure.
It said,
“At the same time, the invocation of this principle must rest upon credible evidence and concrete facts, and not on unsubstantiated allegations or moral conjecture,”
reinforcing the need for strong proof in such sensitive cases.
The bench strongly criticised the High Court for failing to properly assess the facts, stating that a simple reading of the FIR itself proved that the relationship was consensual. According to the Supreme Court, the actions alleged happened within a relationship that was voluntary and mutual at the relevant time.
It clearly stated,
“The continuation of the prosecution in such facts would be nothing short of an abuse of the court machinery,”
concluding that allowing the case to proceed would only harm the justice system.
As a result, the Supreme Court allowed the appeal, quashed the FIR and the charge sheet, and set aside the High Court’s earlier order.
Explaining the background, the Court noted that the complainant had earlier filed a case against her husband and later sought alimony and maintenance. During these legal proceedings, she came in contact with the appellant, who is a practising advocate.
Over time, their professional interaction developed into a close personal relationship. The man expressed his wish to marry her, but due to her difficult marital history, she initially refused.
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Later, the woman became pregnant, and the pregnancy was terminated. When she later insisted on marriage, the man declined, which led to the filing of the rape complaint.
In its final observations, the Supreme Court made it clear that criminal law must not become a weapon in personal relationship disputes and that false allegations of rape weaken the fight against genuine sexual crimes.
The judgment serves as a strong reminder that consent, evidence, and context must always be carefully examined before branding a relationship as a criminal offence.
Case Title:
SAMADHAN S/O SITARAM MANMOTHE vs. THE STATE OF MAHARASHTRA & ANOTHER
CRIMINAL APPEAL NO.5001 OF 2025
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