In a notable judgment passed on March 24, 2025, the Supreme Court of India quashed criminal proceedings in a rape case arising from a failed romantic relationship, finding that the allegations lacked the essential ingredients of the offence and that the prosecution was nothing more than an abuse of judicial process. The case involved a young man accused of rape and cheating by a woman with whom he had been in a prolonged personal relationship, which included repeated private meetings and admitted consensual physical intimacy.
Background of the Case
The matter reached the Supreme Court through a criminal appeal filed against an order of the High Court of Judicature at Madras, which had dismissed a petition seeking quashing of proceedings under Section 482 of the Code of Criminal Procedure (CrPC). The petitioner had sought to put an end to the ongoing trial in S.C. No. 49 of 2022 before the Sessions Judge, Mahila Court, Erode, where he was facing charges under Sections 376 (rape) and 417 (cheating) of the Indian Penal Code (IPC).
According to the statements recorded, the complainant and the accused were closely related and had first met at a family function, where they exchanged phone numbers and continued to be in regular contact. Over time, the relationship became intimate. The complainant stated that she was residing with her grandmother and that the accused began visiting her frequently. The first incident of physical intimacy occurred when the two went to watch a movie and later checked into a hotel. The complainant claimed that she felt dizzy and was coerced into an “abrupt and unexpected” act of intercourse, despite her resistance. It was after this alleged act that a promise of marriage was made, according to her own account.
The complainant further alleged that she was again contacted by the accused to discuss marriage and, on his request, accompanied him to the same hotel. She stated that when she attempted to speak about marriage, the accused refused and instead demanded that intercourse occur first. She alleged that she was again forced into a physical relationship under threat. A third similar incident followed, after which the accused stopped responding to her calls and refused to marry her.
These allegations led to registration of a criminal case and subsequent framing of charges before the Mahila Court.
Legal Proceedings and Submissions
The appellant, through senior counsel, contended that the relationship between the parties was entirely consensual, and that there was no inducement or false promise of marriage preceding the first act of intimacy. It was pointed out that both individuals were majors and had engaged in the relationship over time with mutual consent. The counsel relied on the Supreme Court’s decision in Prithivirajan vs. State, decided on January 20, 2025, where the Court had quashed criminal proceedings in similar circumstances.
The counsel for the State opposed the appeal, arguing that the allegations raised by the complainant required a full trial to ascertain the truth. The complainant’s counsel further argued that the accused had misrepresented his intention to marry, which brought the alleged consent within the mischief of Section 90 of the IPC, making it invalid.
Supreme Court’s Analysis and Findings
The judgment was delivered by Justice Sudhanshu Dhulia and Justice K. Vinod Chandran. The Court meticulously examined the complainant’s First Information Statement and subsequent statements to the police, which formed the foundational material for the prosecution.
In its detailed analysis, the Court noted:
“Unless the ingredients of an offence under Section 376 of the I.P.C. comes forth from these documents… there cannot be any continuation of the prosecution.”
The Court emphasized that the complainant had clearly admitted to repeated interactions and meetings with the accused, including three separate instances of visiting the same hotel with him. These visits were voluntary and spanned over a period, which indicated continued engagement despite the earlier incidents.
Critically, the Court observed:
“From the statements recorded, we do not find any inducement by the accused, with a promise of marriage, before the alleged crime, leading to the sexual intercourse.”
The first alleged promise of marriage, by the complainant’s own version, occurred after the first physical encounter. The Court held that such a promise made post-facto could not be treated as inducement for obtaining consent.
On the claim of coercion and threat, the Court found the narrative inconsistent and lacking in credibility. The complainant stated that she was mentally upset after each incident, yet she continued to respond to the accused’s requests and met him at the same venue multiple times. The Court noted:
“If there is consent, there cannot be alleged forceful intercourse and it could only be contended that consent was obtained on misrepresentation or coercion.”
However, in the present case, the allegations alternated between coercion and misrepresentation, and the Court found these mutually destructive. It added:
“The allegation of forceful intercourse on threat and coercion is also not believable, given the relationship admitted between the parties and the willing and repeated excursions to hotel rooms.”
The Court was categorical in concluding that the complainant’s own version did not support a case of rape or fraudulent inducement:
“We are not convinced that the sexual relationship admitted by both the parties was without the consent of the victim.”
The judgment relied heavily on Prithivirajan vs. State, where the Court had held:
“Letting the appellant face trial would be nothing short of an abuse of the process of the Court. This cannot be permitted.”
Ultimately, the Court allowed the appeal, set aside the High Court’s order, and quashed the proceedings pending before the Sessions Judge. It declared:
“This is precisely a case where the High Court should have interfered in exercise of its inherent and extraordinary powers under Section 482 of the Cr.P.C. These proceedings cannot go on.”
Final Decision
The Supreme Court concluded that:
- There was no evidence of inducement prior to the physical relationship.
- The complainant’s narrative showed a consensual relationship that continued voluntarily.
- The case was a classic misuse of legal process, warranting intervention.
“This is precisely a case where the High Court should have interfered in exercise of its inherent and extraordinary powers under Section 482 of the Cr.P.C. These proceedings cannot go on.”
Accordingly, the Court allowed the appeal and quashed all proceedings in S.C. No. 49 of 2022 pending before the Mahila Court, Erode.
