In a significant ruling, the Supreme Court of India quashed criminal proceedings against Rajnish Singh alias Soni, who was accused of rape, blackmail, and criminal intimidation under the pretext of a false promise of marriage. The Court observed that it was “hard to believe” that a well-educated woman remained in a prolonged 16-year relationship without raising any protest, only to later claim that it was based on deception.
The judgment was delivered by a bench comprising Justice Vikram Nath and Justice Sandeep Mehta in Criminal Appeal No. 2025 (Arising out of SLP (Crl.) No. 8549 of 2023), where the appellant, Rajnish Singh, had challenged the order of the Allahabad High Court dated April 24, 2023. The High Court had dismissed his petition seeking to quash criminal proceedings initiated against him in Criminal Case No. 1246 of 2022 based on an FIR lodged by the complainant at Bakewar Police Station, Etawah.
Background of the Case
The case arose from an FIR registered on July 5, 2022, by the complainant (Ms. A), who alleged that Singh had sexually exploited her under the false promise of marriage since 2006. According to the complainant, the accused, initially a police constable and later a bank employee, repeatedly established physical relations with her while assuring marriage. She further claimed that he drugged her, recorded obscene videos, and blackmailed her for years.
The complainant alleged that she became pregnant during the course of the relationship and was coerced into an abortion. She further stated that Singh extorted money from her under threats of making their intimate videos public. Matters came to a head when Singh married another woman, following which the complainant filed a police complaint.
Legal Issues Involved
Consent and Misconception of Fact: The primary legal question before the court was whether the complainant’s consent to sexual relations was vitiated by a false promise of marriage, thereby constituting rape under Section 376 IPC.
Prolonged Relationship and Voluntariness: Whether a relationship spanning 16 years, during which the complainant and accused met multiple times willingly, could be classified as coercive or non-consensual.
Delayed FIR and Evidentiary Value: The significant delay in filing the FIR—16 years after the alleged first act of sexual intercourse—was also a crucial factor in assessing the veracity of the allegations.
Supreme Court’s Observations and Verdict
A bench comprising Justices Vikram Nath and Sandeep Mehta noted several inconsistencies and contradictions in the complainant’s allegations. The court remarked:
“It is hard to believe that the complainant, being a highly qualified and well-placed major woman, kept on bending to the demands of the appellant for a period of nearly 16 years without raising any protest to any quarter that the appellant was exploiting her sexually under the pretext of a false promise of marriage.”
The court further observed that the complainant and the accused were in a long-standing live-in relationship and that the allegations of force and deceit were implausible given the prolonged and voluntary nature of their association. Citing precedents, the judgment highlighted that consent obtained under a promise of marriage cannot be treated as involuntary unless it is shown that the accused had no intention to marry from the outset.
The court relied on past judgments, including Mahesh Damu Khare v. State of Maharashtra (2024 SCC OnLine SC 3471) and Prashant v. State (NCT of Delhi) (2024 SCC OnLine SC 3375), which held that prolonged consensual relationships could not later be characterized as rape merely because the relationship ended.
“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 the alleged promise made by the accused to marry her.”
Quashing of the FIR
The court ruled that the allegations of rape, extortion, and intimidation were not substantiated by evidence and appeared to be an afterthought. It emphasized that criminal law should not be misused as a tool to settle personal grievances arising from failed relationships.
“The long gap of 16 years between the first alleged act of sexual intercourse, continued relations for one and a half decades till the filing of the FIR convinces us that it is a clear case of a love affair/live-in relationship gone sour.”
Accordingly, the Supreme Court quashed the FIR and all consequential proceedings against the accused, terming the prosecution a “gross abuse of the process of law.”
