The Supreme Court has quashed a rape case filed under Section 376(2)(n) of the Indian Penal Code (IPC), holding that a consensual relationship between adults cannot be turned into a criminal prosecution merely because the relationship later turns sour.
The bench of Justice B.V. Nagarathna and Justice Ujjal Bhuyan observed that allegations of rape on the basis of a promise of marriage must be carefully examined, particularly where both parties were aware of circumstances that made marriage legally impossible.
The case arose from an FIR registered in February 2025 in Bilaspur, Chhattisgarh, where a woman advocate accused another advocate of repeatedly raping her on the false promise of marriage. She alleged that the accused had developed a relationship with her in 2022, assured her of marriage, and engaged in physical relations on multiple occasions.
The complainant further alleged that when she became pregnant, the accused avoided marriage and forced her to terminate the pregnancy. She also claimed that she faced threats and assault when she confronted him and his family.
The High Court had earlier refused to quash the FIR, holding that the issue of consent and false promise required investigation and trial.
The court set aside the High Court’s order and quashed the FIR, the charge sheet, and all criminal proceedings.
The Court noted several crucial facts the complainant was a married woman whose divorce proceedings were still pending during the alleged relationship. Under Indian marriage laws, a person cannot legally marry while a spouse is living, making any promise of marriage legally unenforceable in such circumstances. Both parties were aware of her marital status, making it difficult to accept that consent for the relationship was obtained through deception about marriage.
The Court concluded that the facts indicated a consensual relationship that later turned acrimonious, rather than a criminal offence of rape.
The judgment reiterated settled law that not every breach of a promise to marry amounts to rape. For consent to be considered vitiated, it must be shown that the promise of marriage was false from the very beginning and made solely to obtain sexual relations. Courts must distinguish genuine cases of sexual exploitation from consensual relationships that fail or end in disputes.
The Court also cautioned against the growing tendency to give criminal colour to failed relationships, observing that misuse of rape provisions trivialises the seriousness of the offence and burdens the criminal justice system.
Case Details
Case Title: Pramod Kumar Navratna Versus State Of Chhattisgarh & Others
Case No.: Special Leave Petition (Crl.) No.4452 Of 2025
Date: 05/02/2026
