In a landmark ruling, the Karnataka High Court quashed a rape case filed by a woman who had falsely presented herself as divorced on a dating app. The court held that allegations stemming from consensual relationships, absent deliberate deceit, do not constitute offenses under Section 376 of the Indian Penal Code (IPC).
Justice M. Nagaprasanna, presiding over the case, clarified the distinction between consensual relationships and criminal misconduct based on promises of marriage.
Background
The case involved a relationship formed through a dating platform, where the complainant alleged that she was misled into a physical relationship under the promise of marriage. However, it emerged during the proceedings that the complainant was legally married, contradicting her claim of being divorced. This misrepresentation formed the crux of the petitioner’s defense and influenced the court’s decision.
The relationship ended after the petitioner discovered the complainant’s marital status, leading to the filing of charges under Sections 376 (rape), 420 (cheating), and 506 (criminal intimidation) of the IPC.
Key Legal Questions
1. Misrepresentation of Marital Status: How did the complainant’s marital status affect the allegations of a false promise to marry?
2. Consent and False Promises: Was the complainant’s consent invalidated by the alleged promise of marriage?
3. Breach of Trust vs. Criminal Intent: Did the petitioner’s actions amount to a criminal offense or merely a breach of trust?
Court’s Observations
The High Court observed that the complainant’s misrepresentation fundamentally undermined her claims. Justice M. Nagaprasanna emphasized that the promise of marriage cannot hold legal weight when the complainant is already married. He remarked: “There cannot be a promise of marriage held on to a lady, who was already married. The other acts alleged are all consensual acts. Such consensual acts in a relationship between adults cannot become the offense of rape.”
Referring to the Supreme Court’s judgments, the court reiterated that a false promise to marry must be made with intent to deceive from the outset to vitiate consent under Section 375 IPC.
Supreme Court Precedents
The judgment drew on pivotal rulings, including:
– Pramod Suryabhan Pawar v. State of Maharashtra, which distinguished consensual relationships from rape claims based on false promises of marriage.
– Deepak Gulati v. State of Haryana, which emphasized that relationships based on mutual affection do not constitute criminal offenses, even if they later fail.
These precedents clarified the legal threshold for distinguishing consensual relationships from cases of criminal exploitation.
The court quashed the case, ruling that the allegations lacked sufficient grounds for criminal prosecution. It affirmed that consensual relationships, even when marred by disappointment, cannot be construed as criminal acts without evidence of deliberate deceit.
