A) ABSTRACT / HEADNOTE

Rajnish Singh @ Soni v. State of U.P. and Another, [2025] 3 S.C.R. 303 (Hereinafter “the Judgment”) examines whether prolonged consensual sexual relations, begun after an initial alleged promise of marriage, can sustain criminal liability for rape where the prosecutrix later contends her consent was vitiated by a false promise. The Supreme Court, after reviewing the FIR, statements and investigation, and applying precedent (notably Mahesh Damu Khare v. State of Maharashtra, Prashant v. State (NCT of Delhi), Deepak Gulati v. State of Haryana and Shivashankar v. State of Karnataka), held that the material facts demonstrated a long-standing consensual relationship spanning approximately sixteen years and that the complainant had frequently represented herself as the appellant’s wife.

The Court therefore concluded that the requisite causal link that the sexual relations were purely traceable to a false promise of marriage and were maintained throughout by a misconception of fact was lacking. The impugned criminal proceedings under Sections 376, 384, 323, 504 and 506 IPC were quashed as an abuse of process. This analysis is based exclusively on the judgment and record provided.

Keywords: quashing of criminal proceedings, promise of marriage, vitiation of consent, consensual intercourse, abuse of process.

B) CASE DETAILS 

i) Judgment Cause Title: Rajnish Singh @ Soni v. State of U.P. and Another.
ii) Case Number: Criminal Appeal No. 1055 of 2025.
iii) Judgment Date: 03 March 2025.
iv) Court: Supreme Court of India.
v) Quorum: Hon’ble Justices Vikram Nath and Sandeep Mehta (Mehta, J. author).
vi) Author: Mehta, J.
vii) Citation: [2025] 3 S.C.R. 303
viii) Legal Provisions Involved: Sections 376, 384, 323, 504, 506 IPC; Section 482 CrPC (quashing jurisdiction); reference to Section 173(2) CrPC (police report).
ix) Judgments overruled by the Case (if any): None.
x) Related Law Subjects: Criminal Law (Sexual Offences), Evidence, Procedure (quashing under Section 482 CrPC), Principles of consent and misconception of fact.

C) INTRODUCTION AND BACKGROUND OF JUDGEMENT

The appellant faced criminal proceedings arising from an FIR dated 5 July 2022 alleging, inter alia, forcible sexual intercourse in 2006, recordings of intimate acts, coercion, causing miscarriage and blackmail, culminating in charges under Sections 376, 384, 323, 504 and 506 IPC. The police submitted a chargesheet under Section 173(2) CrPC and the Magistrate took cognizance. The appellant sought quashing under Section 482 CrPC, contending the allegations were a manufactured colouration of a prolonged consensual relationship. The High Court dismissed the quash petition and the appellant approached the Supreme Court.

The core contest before the Court was legal: whether prolonged sexual relations, begun after an alleged promise of marriage, could amount to rape under Section 376 IPC where the complainant later claims consent was vitiated by a false promise. The factual matrix included long intermissions of consensual association, alleged circulation threats via video, allegations of drugging in 2009, an abortion claim, financial extortion by cheque, and the appellant’s subsequent marriage to another woman in April 2022, which prompted the FIR. Investigation narrowed culpability to the appellant and deleted Section 313 IPC (causing miscarriage). The Court examined credibility, delay, conduct over sixteen years and applied binding precedents to assess whether consent remained vitiated or was a product of mutual, sustained consent.

D) FACTS OF THE CASE

The complainant, Ms. A, an adult woman holding M.Com and B.Ed. qualifications and employed as a lecturer, alleged first forcible intercourse in 2006 at her house; she claimed the appellant gagged her and, on being warned, promised marriage. Thereafter the parties allegedly entered a prolonged sexual relationship that continued intermittently through 2006–2021. The complainant asserted that in 2009 at the appellant’s residence he drugged her, recorded obscene videos and later used those materials to blackmail her into continued intercourse; she contends a subsequent pregnancy was terminated by medicines administered by the appellant.

Financial coercion is alleged (a Rs.94,000 cheque in 2011). The complainant approached a One Stop Centre on 23 March 2022; though an agreement to marry was reportedly reached then, the appellant married Namrata on 22 April 2022. On learning of that marriage the complainant filed the FIR on 5 July 2022. Investigation deleted the abortion-related charge and limited charges to the appellant under Sections 376, 384, 323, 504 and 506 IPC. Material on record shows the complainant repeatedly portrayed herself as married to the appellant in prior representations and that the relationship endured across different postings of the parties, sometimes with the complainant travelling to the appellant’s place of posting.

E) LEGAL ISSUES RAISED

i. Whether prolonged sexual relations, initially premised on an alleged promise of marriage, amount to rape when consent is later alleged to have been procured by a misconception of fact?
ii. Whether the facts demonstrate the appellant had mala fide intention from the inception so as to criminalize the breach as rape?
iii. Whether the continuation of intimacy over many years renders the prosecutrix’s allegation of deception ex facie unbelievable, justifying quashing under Section 482 CrPC?
iv. Whether allowing prosecution to continue would amount to abuse of process of law in the present facts?

F) PETITIONER / APPELLANT’S ARGUMENTS

The counsel for the appellant argued that the entire FIR was false and concocted. The complainant, an adult and educated woman, willingly maintained intimate relations for about sixteen years; the intercourse was consensual and not attributable to any continuing misconception of marriage. The appellant asserted a genuine intention to marry and pointed to a private informal marriage ritual and the complainant’s earlier applications representing herself as his wife (application dated 25 May 2022), to demonstrate absence of deceit. The prolonged conduct, mutual visits and the complainant’s travel to meet the appellant were relied upon to show voluntary association and to characterise the prosecution as a love-affair gone sour.

G) RESPONDENT’S ARGUMENTS

The State and complainant contended that the appellant obtained consent on the basis of false assurances of marriage and thereafter exploited the complainant through blackmail using recorded intimate videos. They stressed the drugging incident, coerced abortion, repeated threats and forcible sexual acts as demonstrating absence of consent and presence of mala fide intent. The prosecution argued that the High Court correctly refused quashing given the gravity and character of allegations, which merited full trial and evidence.

H) JUDGEMENT

The Court scrutinized delays, conduct and the probative matrix. The I.O. had excluded the abortion charge (Section 313 IPC) and restricted the chargesheet mainly to the appellant. The Court emphasised established principles: to convict for rape predicated on false promise of marriage the sexual intercourse must be directly traceable to the promise and not qualified by other considerations; mere breach of promise does not ipso facto constitute rape.

The Court found material contradictions and noted that the complainant, despite alleging an inaugural forcible assault in her parental home in 2006, did not contemporaneously disclose the crime, which undermined credibility. The prolonged, uninterrupted association stretching nearly sixteen years, interspersed with mutual representations (including conduct indicating living together and the complainant portraying herself as wife), led the Court to infer longstanding consensual relations.

Reliance on Mahesh Damu Khare and Prashant supported the view that prolonged intimate association rebuts an inference that consent throughout was vitiated by a false promise. The Court held that the complainant’s later resort to criminal law after learning of the appellant’s marriage to a third party suggested personal grievance rather than a continuing inability to consent. On this canvas the Court concluded that to permit prosecution to continue would be a gross abuse of process and quashed the FIR and ensuing proceedings under Sections 376, 384, 323, 504 and 506 IPC.

a. RATIO DECIDENDI

The decisive ratio is that where sexual relations persist over a long period with the complainant acting, at times, as the appellant’s wife and voluntarily travelling or receiving visits, the factual inference of continuous vitiation of consent by a false promise of marriage is untenable. The Court applied the doctrine from Deepak Gulati that criminal liability for rape on account of false promise requires proof that the accused from the inception had no intention to marry and that the relationship was purely because of the misrepresentation. Where other considerations love, passion, long mutual association, implied consent play a significant role over years, the causal link to a single false promise is broken. Precedents such as Mahesh Damu Khare and Prashant were applied to hold that prolonged consensual intimacy negates the contention of sustained misconception of fact.

b. OBITER DICTA 

The Court observed, obiter, on credibility factors that: extreme delay, inconsistent statements (portraying herself as wife at times), and lack of contemporaneous complaint militate against accepting allegations at face value. The judgment reiterated judicial caution in distinguishing a breach of promise from rape, stressing that courts must examine mala fide intent at the initial promise stage and not convert every failed matrimonial expectation into a criminal charge. The opinion also implied sensitivity to potential misuse of criminal law to settle personal scores after relationships sour.

c. GUIDELINES

The Court reiterated and elaborated practical guidelines: first, courts must examine whether sexual intercourse was directly traceable to a promise of marriage and whether such promise was accompanied by mala fide intention from inception. Second, where relations span years with voluntary actions by the complainant (travel, mutual representations), the inference of continual coercion is weakened. Third, delays and contradictory conduct are relevant to the exercise of Section 482 CrPC; if prosecution would result in manifest abuse, quashing is appropriate. Fourth, deletion of certain charges by Investigating Officer (e.g., miscarriage charge) narrows the factual matrix and must be factored in quash petitions. These guidelines flow from precedents cited in the judgment and are articulated to prevent criminal process from being weaponised in protracted consensual relationships that later deteriorate.

I) CONCLUSION & COMMENTS

The Judgment underscores an evidentiary and doctrinal boundary: not every breach of matrimonial promise converts consensual intercourse into rape. The Court’s quashing is anchored on prolonged voluntary conduct, contradictions in the complainant’s narrative, delay, and the investigative narrowing of charges. The decision vindicates the principle that criminalizing private consensual relations requires clear evidence of mala fide intention at the outset and of a causal nexus between deception and each act of intercourse. However, the ruling also highlights the fine, fact-sensitive line courts must tread so as neither to trivialise genuine sexual exploitation nor permit misuse of criminal law. Practitioners should note that the judgment reinforces careful judicial appraisal of delays, contemporaneous conduct, and whether the intercourse was “purely” on account of the false promise. The case will guide trial courts and quashing jurisprudence on distinguishing consensual long-term relationships from crimes of deception.

J) REFERENCES

a. Important Cases Referred

1. Rajnish Singh @ Soni v. State of U.P. and Another, [2025] 3 S.C.R. 303.

2. Mahesh Damu Khare v. State of Maharashtra, 2024 SCC OnLine SC 3471.

3. Prashant v. State (NCT of Delhi), 2024 SCC OnLine SC 3375.

4. Deepak Gulati v. State of Haryana, (2013) 7 SCC 675.

5. Shivashankar v. State of Karnataka, (2019) 18 SCC 204.

b. Important Statutes Referred

1. Indian Penal Code, 1860 — Sections 376, 384, 323, 504, 506, 313, 90.

2. Code of Criminal Procedure, 1973 — Sections 161, 164, 173(2), 482.