A) Abstract / Headnote

The Supreme Court addressed whether the High Court erred in refusing to exercise its inherent jurisdiction under Section 482 of the Code of Criminal Procedure, 1973 (CrPC) to quash an FIR under Section 376 IPC based on allegations of rape on a false promise of marriage. The Court held that the FIR allegations did not establish a prima facie case for rape as the relationship spanned over five years, during which the complainant and the appellant cohabited as husband and wife. This long consensual relationship negated any initial promise of marriage inducing consent for sexual relations. Additionally, the delay in filing the FIR and subsequent developments, including the omission of allegations under Section 313 IPC, rendered the FIR untenable. Consequently, the Court quashed the FIR to prevent abuse of judicial process.

Keywords: Section 482 CrPC, quashing, false promise of marriage, consensual physical relationship, delay in FIR, Section 376 IPC.

B) Case Details

i) Judgment Cause Title:
Lalu Yadav v. The State of Uttar Pradesh & Ors.

ii) Case Number:
Criminal Appeal No. 4222 of 2024

iii) Judgment Date:
16 October 2024

iv) Court:
Supreme Court of India

v) Quorum:
Justice C.T. Ravikumar and Justice Rajesh Bindal

vi) Author:
Justice C.T. Ravikumar

vii) Citation:
[2024] 10 S.C.R. 639

viii) Legal Provisions Involved:

• Section 482, Code of Criminal Procedure, 1973
• Section 376, Indian Penal Code, 1860
• Section 313, Indian Penal Code, 1860

ix) Judgments Overruled by the Case:
None

x) Related Law Subjects:
Criminal Law, Abuse of Judicial Process, Rape Allegations, Procedural Law

C) Introduction and Background of Judgment

The judgment arose from the dismissal of a writ petition by the Allahabad High Court, refusing to quash an FIR registered under Sections 376 and 313 IPC. The complainant alleged rape by the appellant under a false promise of marriage spanning five years (2013–2018). After the appellant refused to marry her following his employment, she lodged an FIR in 2018. The appellant contended that their relationship was consensual and based on mutual understanding, not on any inducement or fraud.

The High Court relied on legal precedents emphasizing the need for caution in quashing criminal proceedings, noting that an FIR can only be quashed if allegations do not disclose a prima facie cognizable offense. However, the appellant argued that the FIR allegations, delay in filing, and factual inconsistencies warranted interference under Section 482 CrPC to prevent judicial abuse.

D) Facts of the Case

The complainant alleged that the appellant promised to marry her in 2013 and established a physical relationship without her consent. Over five years, they cohabited as husband and wife, with the appellant making repeated promises of marriage. The appellant’s refusal to marry her following his employment led to the FIR under Sections 376 and 313 IPC.

The FIR noted significant delays:

1. The alleged acts spanned from January 2013 to January 2018.
2. The FIR was lodged in February 2018.

The complaint also included allegations of forced abortion, which were later found baseless by the investigating agency. The prosecution omitted charges under Section 313 IPC in 2024.

E) Legal Issues Raised

1. Whether the allegations in the FIR disclosed a prima facie case under Section 376 IPC.
2. Whether the High Court erred in not quashing the FIR under Section 482 CrPC.
3. Whether a delay of five years in filing the FIR affected its validity.
4. Whether the relationship was consensual or based on inducement by a false promise of marriage.

F) Petitioner/Appellant’s Arguments

The counsel for the appellant argued:

1. Delay in FIR: The complainant took five years to report the alleged offenses, undermining their credibility.
2. Consensual Relationship: The complainant voluntarily cohabited with the appellant as his wife for years, establishing a consensual physical relationship.
3. No Misrepresentation: The promise of marriage, even if made, did not amount to deceit warranting Section 376 IPC prosecution.
4. Legal Precedents: Relied on cases such as Shivashankar alias Shiva v. State of Karnataka (2019) and Naim Ahamed v. State (NCT of Delhi) (2023) to argue that consensual relationships cannot be construed as rape due to subsequent refusal to marry.

G) Respondent’s Arguments

The State and the complainant contended:

1. Promise of Marriage: The appellant induced the complainant into a physical relationship by promising marriage, violating Section 375 IPC.
2. Factual Discrepancies: Delay in filing the FIR was justified due to the appellant’s repeated promises and the complainant’s belief in eventual marriage.
3. Jurisdictional Restraints: The High Court was correct in dismissing the writ petition, as the FIR disclosed prima facie cognizable offenses warranting investigation.

H) Related Legal Provisions

1. Section 482, CrPC: Powers of High Courts to prevent judicial process abuse and secure justice.
2. Section 376, IPC: Punishment for rape, encompassing coercion or deceit.
3. Section 313, IPC: Offense related to causing miscarriage without the woman’s consent.

I) Judgment

a. Ratio Decidendi

The Court held that allegations in the FIR failed to establish a prima facie case under Section 376 IPC due to:

1. Consensual Relationship: Evidence showed a prolonged cohabitation akin to marriage, negating coercion or deceit.
2. Delay in FIR: The unexplained five-year delay cast doubt on the complainant’s claims.
3. Lack of Misrepresentation: No evidence suggested the appellant induced the relationship under false promises.

b. Obiter Dicta

The Court observed that the complainant’s narrative revealed inconsistencies, highlighting the importance of early reporting to preserve credibility in sexual offense allegations.

c. Guidelines

1. FIRs alleging rape on false promises of marriage require scrutiny for prima facie evidence.
2. Delays in filing FIRs, absent justification, weaken the complainant’s case.

J) References

a. Important Cases Referred

1. State of Haryana v. Bhajan Lal, AIR 1992 SC 604
2. Pepsi Foods Ltd. v. Special Judicial Magistrate, (1998) 5 SCC 749
3. Shivashankar alias Shiva v. State of Karnataka, (2019) 18 SCC 204
4. Naim Ahamed v. State (NCT of Delhi), 2023 SCC OnLine SC 89

b. Important Statutes Referred

1. Code of Criminal Procedure, 1973
2. Indian Penal Code, 1860