New Delhi: The Supreme Court of India has quashed the conviction and sentence of a man accused of rape on the pretext of a false promise of marriage, following the marriage of the accused and the prosecutrix during the pendency of the appeal. The Court invoked its powers under Article 142 of the Constitution to do complete justice, observing that the case arose from a misunderstanding in a consensual relationship.
The matter reached the Supreme Court via a Criminal Appeal filed by the appellant challenging the order of the Madhya Pradesh High Court which had rejected his application for suspension of sentence. The appellant had been convicted under Sections 376(2)(n) (repeated rape) and 417 (cheating) of the Indian Penal Code (IPC).
The Supreme Court bench comprising Justice B.V. Nagarathna and Justice Satish Chandra Sharma, upon being informed that the parties had married on July 22, 2025, and were residing together, quashed the FIR, the conviction, and the sentence. The Court also ordered the restoration of the appellant’s service benefits.
Background of the Case
According to the judgment, the appellant met the prosecutrix (second respondent) in 2015 on a social media platform. They developed a liking for each other and entered into a “consensual physical relationship.” The prosecutrix alleged that she acted on the “alleged false promise of marriage” given to her by the appellant.
Aggrieved by the non-fulfillment of the promise to marry, she filed FIR No. 29 of 2021 on November 2, 2021, at the Women Police Station, District Sagar, Madhya Pradesh. A chargesheet was subsequently filed on February 8, 2022.
The trial was conducted by the Additional Sessions Judge in Sessions Trial No. 191 of 2022. On April 12, 2024, the Trial Court convicted the appellant and sentenced him to rigorous imprisonment for ten years with a fine of Rs. 50,000 for the offence under Section 376(2)(n) IPC, and rigorous imprisonment for two years with a fine of Rs. 5,000 for the offence under Section 417 IPC.
The appellant appealed to the Madhya Pradesh High Court (CRA No. 4869 of 2024) and sought suspension of his jail sentence via I.A. No. 9352 of 2024. The High Court rejected this application, prompting the appeal before the Supreme Court.
Supreme Court’s Intervention and Subsequent Marriage
The Supreme Court noted that this was a “rare case” where its intervention led to the quashing of the conviction. The Bench observed that upon considering the facts, they sensed a possibility of reconciliation.
“We had a sixth sense that the appellant and the respondent prosecutrix could be brought together once again if they decided to marry each other,” the Court observed.
Acting on this, the Court suggested the parties seek instructions. Following interactions in the Judges’ Chamber with their parents present, both parties expressed their willingness to marry. The Court granted interim bail to the appellant on May 15, 2025, to facilitate the marriage.
During the hearing on July 25, 2025, the counsel for the parties informed the Court that the marriage had been solemnized on July 22, 2025, and the couple had been residing together since then. The prosecutrix submitted that she did not wish to continue the criminal proceedings.
Court’s Analysis and Decision
The Bench concluded that the criminal proceedings were the result of a misunderstanding between parties who intended to marry but faced delays.
“We think that owing to a misunderstanding the consensual relationship between the parties was given a criminal colour and converted into an offence of false promise of marriage whereas the parties, in fact, intended to marry each other. It was only owing to the appellant seeking postponement in the date of marriage which may have led to insecurity in the mind of the respondent prosecutrix and filing of the criminal complaint,” the Bench stated.
Expressing satisfaction with the outcome, the Court invoked its extraordinary powers under Article 142 of the Constitution of India to quash the proceedings “in the interest of justice and to do complete justice.”
The Court ordered:
- The quashing of FIR No. 29 of 2021 lodged with Women Police Station, District Sagar.
- The quashing of the judgment and order of conviction and sentence dated April 12, 2024, passed by the I Additional Sessions Judge, Sagar.
- The appeal pending before the Madhya Pradesh High Court (CRA No. 4869 of 2024) was rendered infructuous.
Directions on Service Matters
The counsel for the appellant submitted that the appellant had been suspended from his service due to the criminal case and conviction. He requested a direction for the revocation of suspension and payment of arrears.
The Supreme Court directed the Chief Medical Officer (CMO), Sagar, Madhya Pradesh, to revoke the suspension order and pay the arrears of salary to the appellant within two months, noting that the appellant had joined duty pursuant to the revocation.
Case Details:
- Case Name: Sandeep Singh Thakur vs. State of Madhya Pradesh & Another
- Case No: Criminal Appeal No. 5256 of 2025
- Bench: Justice B.V. Nagarathna and Justice Satish Chandra Sharma
